Held that:

• The limitation for passing the revisional order under S. 263 of the Act has to be counted from the date of order passed pursuant to the directions of CIT(A) (for allowing MAT credit) and cannot be counted from the date of the original assessment order.
• Order giving effect to CIT(A)’s order for allowing MAT credit as per law, cannot be considered to be merely an order following directions and hence initiation of revisional proceedings under S. 263 of the Act cannot be vitiated on this ground.
• There being no restriction with regard to allowance of MAT credit of an amalgamating company at the hands of amalgamated company (assessee), the CIT was not justified in exercising his revisional power under S. 263. (AY. 2007-08)