Date of original assessment order considered for limitation period for revisionary proceeding u/s. 263

CIT Vs Ganga Textiles Ltd. (Madras High Court) Madras High Court held that order passed u/s. 263(1) is with reference to issue covered by the original assessment order and not reassessment. Hence, limitation of two years prescribed u/s. 263(2) of the Act has to be reckoned from the date of the original assessment order. Accordingly, order is time barred. Facts- Respondent/Assessee is a limited company. Original assessment order was passed on 31.08.2006. The assessment was reopened and was completed u/s. 143(3) r.w.s 147 of the Act on 30.12.2009 qua computation of capital gains regarding assess...