Held dismissing the appeal, the Court held that the Commissioner had exercised powers under section 263 of the Act with respect to issues which were not covered in the reassessment proceedings. Therefore, the issues before the Commissioner while exercising the powers under section 263 of the Act related back to the original assessment order and, therefore, the limitation would start from the original assessment order and not from the reassessment order. Followed, CIT v. Alagendran Finance Ltd (2007) 293 ITR 1 (SC)/ (2007) 7 SCC 215
CIT v. Industrial Development Bank of India Ltd. (2023)454 ITR 811/333 CTR 570 (SC) Editorial: CIT v. Industrial Development Bank of India Ltd(Bom)(HC) (ITA (L) No. 2115 of 2007 dt. 7-5 2009 ), affirmed.
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Limitation-Issues not covered in reassessment proceedings-Limitation to be reckoned from date of original assessment and not of reassessment. [S. 147, 148]