Held that revision order against the order under 147 is barred by the limitation as the issue raised in revisionary proceedings are different from the reassessment issue under section 147. The time limit to be ascertained from 143(1) order and not from the order under section 147 of the Act. Relied on Alagendran Finance Ltd v.PCIT (2007) 293 ITR 11 (Mad) (HC), Indira Industries Ltd v.PCIT (2018] 95 taxmann.com 292 (Mad)(HC), CIT v. Lark Chemicals Ltd (2014) 368 ITR 655(Bom)(HC), PCIT v. Lark Chemicals Ltd (2018) 259 Taxman 365 (SC) (AY. 2016-17)(ITA No. 2923/ Mum/ 2024 dt. 30-10-2024)
Indian Education Society v. CIT(E) (2024) Chamber’s Journal-December-P. 105 (Mum)(Trib)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Barred by limitation-Issue raised in the revision proceedings are different from re-assessment issue under section 147 of the Act-Time limit to be ascertained from 143(1) order and not under section 147 of the Act-Order is barred by limitation.[S.143(1), 147, 148]
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