Court Rules Revision Period for Tax Cases Starts from Reassessment Order, Not Original Assessment, Invalidating Proceedings.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....The Rajasthan High Court examined the validity of revision proceedings u/s 263 concerning the period of limitation. The issue was whether the period of limitation for passing the order u/s 263 should be reckoned from the date of the original assessment order or the date of the reassessment order. The Court referred to the Supreme Court's judgment in the case of Industrial Development Bank of India Ltd. and followed the decision in the case of Chambal Fertilisers and Chemicals Limited. It was held that once the reassessment of the escaped assessment occurred, the revision would have the same limited ambit for the purpose of limitation prescribed in Section 263(2) of the Income Tax Act of 1961, which is two years. The Court noted that the pet.........