Limitation period to be reckoned from Date of Revision order passed by AO U/s. 143(3) RW Section 263

PCIT Vs Apeejay Shipping Ltd. (Calcutta High Court)

The Tribunal rightly held that the period of limitation for the assessment year 2007-08 has to be reckoned from the date of the order passed by the Assessing Officer under Section 143(3) read with Section 263 i.e. 8th December, 2011 and not from the date of the order passed by the Assessing Officer under Section 143(3) read with Section 263 and 251 dated 29th November, 2012.

FULL TEXT OF THE JUDGMENT/ORDER OF CALCUTTA HIGH COURT

The Court : This appeal of revenue filed under Section 260A of the Income Tax Act (the ‘Act’ in brevity) is directed against the order dated 6th April, 2016 passed by the Income Tax Appellate Tribunal, A-Bench, Kolkata (the ‘Tribunal’) in ITA Nos.781, 782, 783 & 784/Kol/2015 for the assessment years 2007-08, 2008-09, 2009-10 and 2010-11.

The revenue has raised the following substantial questions of law for consideration :

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