Limitation Period for Revision Orders u/s 263: Linked to Re-assessment or Original Assessment Date?

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....Revision u/s 263 - period of limitation for passing order - Only in a case where the issues before the Commissioner at the time of exercising powers u/s 263 relate to the subject matter of re-assessment, the limitation would start from the date of Re-assessment Order. However, if the subject matter of the re-assessment is distinct and different, in that case the relevant date for the purpose of determination of period of limitation for exercising powers u/s 263 would be the date of the original Assessment Order. - SC....