2 year limitation period u/s 263(2) runs from date of original assessment and not from the date of reassessment

M/s Indira Industries Vs. PCIT (Madras High Court)

The principles and the grounds available for assailing a show-cause notice are now well settled. If the authority issuing the show-cause notice lacks jurisdiction and if it is clearly barred by law, it certainly renders the show-cause notice invalid in law. In the instant case, owing to all that have been stated supra, as the impugned notice, though is a show-cause notice as noticed by the learned single Judge, is inval

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