Limitation period u/s. 263 would be from date of original assessment order as reassessment order is distinct

Jainsons Agrochem Industries Vs PCIT (Rajasthan High Court) Rajasthan High Court held that since reassessment order is distinct and different, the period of limitation for exercising powers u/s. 263 of the Income Tax Act would be the date of original assessment order. Thus, entire proceedings barred by limitation. Facts- The petitioner filed his income tax return declaring a total income of Rs.4,98,43,110/-. The petitioner has also reflected a Dividend income of Rs.21,58,735/- received from investment in Mutual Funds of UTI Ltd. and tax paid on the short term capital gain. Upon the scrutiny of...