Param Transport (P.) Ltd. v. PCIT (2019) 102 taxmann.com 327 (Chhattishgarh) (HC) Editorial: SLP of assessee is dismissed, Param Transport (P.) Ltd. v. PCIT (2019) 261 Taxman 346 (SC)

S. 153 : Assessment–Reassessment–Limitation–Revision- Revisionary powers could be exercised by Commissioner in all cases where assessment was made and once he exercised his revisionary powers then provisions of section 153(2A) would be applicable and, limitation would be one year from date of order being passed by Commissioner in revision petition. [S. 153(2A), 153B, 153C, 263]

A search was carried out on 4-2-2010. Assessment year ended on 31-3-2010 and 21 months period expired on 31-12-2011. Assessments were made on 30-12-2011. Commissioner passed the revision order on 28-3-2014.  The asessee contended that period for making assessment was over, no fresh assessment could actually be done because it was beyond period of limitation on the ground that the benefit of sub-section (2A) could not be availed of to extend limitation in cases where Commissioner exercised power under section 263 where assessment was pursuant to search operations carried out in terms of section 153A. High Court held that revisionary powers could be exercised by Commissioner in all cases where assessment was made and once he exercised his revisionary powers then provisions of section 153(2A) would be applicable and, limitation would be one year from date of order being passed by Commissioner in revision order. Accordingly the revision order was up held.