Section 263 Limitation Runs From Original Assessment if Reassessment Issues Are Different: SC

CIT-3 Vs Industrial Development Bank of India Ltd (Supreme Court of India) The Supreme Court dismissed the Revenue’s appeal challenging the Bombay High Court judgment which had upheld the ITAT’s finding that proceedings initiated by the Commissioner under Section 263 of the Income Tax Act, 1961 were barred by limitation. The central issue before the Court was whether the limitation period for passing an order under Section 263 should be calculated from the date of the original assessment order or from the date of the reassessment order. The Court noted that the Commissioner had exercised p...