Section 263 not mandate service of order Within Two Years: SC

CIT Vs Mohammed Meeran Shahul Hameed (Supreme Court)  On a fair reading of sub­section (2) of Section 263 it can be seen that as mandated by sub­section (2) of Section 263 no order under Section 263 of the Act shall be ‘made’ after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. Therefore the word used is ‘made’ and not the order ‘received’ by the assessee. Even the word ‘dispatch’ is not mentioned in Section 263 (2). Therefore, once it is established that the order under Section 2...