Tribunal held that the issue of production of coal mines was not an issue in the reopened assessment proceedings. The precise issues for which action under section 263 was initiated were for assessing the income of the assessee on account of showing the incorrect production according to the report of a commission of inquiry. Action under section 263 was not initiated in respect of the deduction of the assessee under section 80-IA or 80-IB . Therefore, the issue for which revision under section 263 was proposed was not the issue for which the case of the assessee was reopened under section 147 . Action under section 263 was initiated on issues which had already been decided in the original assessment and not in the reopened assessment. Therefore, the time limit for passing the order under section 263 would run from the date of the original order and not that of the subsequently reopened assessment order under section 147 . The original assessment order was passed on January 16, 2014, and revision thereof could have been taken up to March 31, 2016. The order under section 263 was passed on February 26, 2019, and therefore it was clearly beyond the limitation prescribed under section 263(2) .( AY.2009-10)