The assessment order was passed in the year 2013 and the Commissioner (E) had issued notice under section 263 of the Act on March 11, 2016. Order is barred by limitation. The Assessing Officer had not made any addition on the ground mentioned in the reasons recorded. Where no addition is made on the grounds mentioned in the reasons recorded for reopening of the assessment, the assessment order cannot be said to be erroneous under section 263 of the Act. (AY.2011-12)
Karmae Garchen Trust v. JCIT (2021) 92 ITR 365 (2022) 209 DTR 361 (Chd.)(Trib.)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Limitation-No addition was made on the ground mentioned in recorded reasons-Limitation to be reckoned from date of original assessment. [S. 12AA(1)(b), 147, 148]