Held that  issue was not a subject matter of discussion either in the original assessment proceedings under section 143(3) or in first round of 263 proceedings. When an issue which was not subject matter of any other proceedings, the period of limitation was to run from the original assessment order passed under section 143(3) of the Act for the purpose of invoking jurisdiction under section 263 of the Act. The original assessment order was passed on December 22, 2009 and the Principal Commissioner could issue a show-cause notice on or before March 31, 2012. The Principal Commissioner had issued the show-cause notice on February 9, 2015, which was clearly beyond the period of two years provided under the Act. Therefore, assumption of jurisdiction by the Commissioner on this issue for revision of assessment order under section 263 of the Act was clearly barred by limitation, bad in law and liable to be quashed. (AY.2007-08)