Section 263 Revision Time-Barred as Lease Equalization Fund Was Not Subject of Reassessment: SC

CIT Vs Alagendran Finance Ltd. (Supreme Court of India) The Supreme Court examined whether, for the purpose of limitation under Section 263(2) of the Income Tax Act, 1961, the relevant date should be the original assessment order or the reassessment order. The assessee company had filed returns for assessment years 1994-95, 1995-96, and 1996-97, and original assessments were completed between 1997 and 1998. In those assessments, the claim relating to “Lease Equalization Fund” was accepted. Subsequently, reassessment proceedings were initiated only on issues relating to share issue expenses...