Limitation for Section 263 Starts from Original Assessment Date if issues under review not pertain to reassessment

Shiv Vegpro Pvt. Ltd. Vs PCIT (ITAT Jaipur)

The Income Tax Appellate Tribunal (ITAT) Jaipur has ruled in favor of the assessee, Shiv Vegpro Pvt. Ltd., by setting aside the Principal Commissioner of Income Tax (PCIT)’s order under Section 263 of the Income Tax Act, 1961, on grounds of limitation. The case centered around whether the limitation period for invoking Section 263 should be calculated from the date of the original assessment order or the reassessment order.

Shiv Vegpro Pvt. Ltd. had initially filed its return of income on September 6, 2017, and an intimation

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