The assessment was completed u/s. 143(3) of the Act on 28th December 2006. The reassessment was completed on 30 the December 2011. The revision order was passed on 26th March 2014. The Tribunal held that the issue which was not subject matter of reassessment while computing the limitation the issue which was was not subject matter of reassessment limitation has to be computed from the original assessment-Revision was held to be barred by limitation. Relied on CIT v. Alagendran Finance Ltd. (2007) 293 ITR 1(SC), Asoka Buildcon Ltd v. ACIT (2010) 325 ITR 574 (Bom.)(HC), CIT v. ICICI Bank Ltd (2012) 252 CTR 85 (Bom)(HC) (AY. 2004-05)
CIT v. Indian Overseas Bank (2021) 207 DTR 202/(2022)441 ITR 689 (Mad.)(HC)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Limitation-Reassessment-Issue which was not subject matter of reassessment limitation has to be computed from the original assessment-Revision was held to be barred by limitation. [S. 143(3), 147, 263(2)]