Section 263 limitation period – When issue was discussed only in Original Assessment Order

Jindal Steel & Power Ltd. Vs PCIT (ITAT Delhi) Admittedly in the present case the case of the assessee which was earlier assessed by the order passed by under section 143 (3) of the income tax act on 16/01/2014 which was passed in pursuance of the draft assessment order subject to the direction of The Dispute Resolution Panel. Therefore if any issue which is found not have been dealt with or erroneously dealt with by the l d AO and if it is subject to revision u/s 263 of the act, than the requisite action should have been concluded by 31.03.2016 [i.e. within two years from the end of the y...