Limitation for Revision Under IT Act Sec 263 Starts from Original Assessment Date, Not Re-Assessment Date.

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....Revision u/s 263 - period of limitation - To be calculated from the date of original assessment or from the date of re-assessment after reopening - the issue on which the ld. PCIT proposed the revision of order framed u/s 144 r.w.s. 147 dated 29.09.2021, in which these two scrips were not the subject matter of re-assessment proceedings. Therefore, the period of limitation has to run from the date of assessment as framed under section 143(1) dated 18.06.2013 - AT....