Limitation period for revisional proceeding in case of both Assessment & Reassessment

CIT Vs Indian Overseas Bank (Madras High Court) The question as to whether the date, on which the order under Section 147 of the Act was passed should be reckoned as the starting point of limitation, considering the facts and circumstances of the case, has been dealt with by several decisions of the Hon’ble Supreme Court and the earliest of such decisions is in the case of CIT Vs. Alagendran Finance Limited [reported in (2007) 293 ITR 1] wherein it was held that in respect of an issue, which was not subject matter of reassessment, limitation under Section 263(2) of the Act would run from...