HC dismisses Section 263 notice on the ground of Limitation

PCIT Vs Prince Water House (Calcutta High Court) Order dated 23.03.2015 passed by the AO giving effect to the directions of the tribunal dated 04.03.2014 (passed u/s 254 r.w.s 143(3) of the Act) did not deal with the issue of allowability of premium on account of Accountants Risk Policy. The show cause notice u/s 263 of the Act purports to revise the order dated 27.02.2017 and subsequent order dated 13.04.2015 passed u/s 254 r.w.s143(3) of the Act and in these orders the AO did not deal with the premium paid on account of Accountants Risk Policy nor was it subject matter of those proceedings. ...