The Commissioner invoked revisionary jurisdiction under section 263 in respect of issues concluded by an intimation issued under section 143(1), though a reassessment under section 147 had subsequently been completed on unrelated issues. The Tribunal held that, where the subject matter of revision pertained to the original intimation under section 143(1), the limitation prescribed under section 263 had to be computed from the date of such intimation and not from the subsequent reassessment order. As the revision order was passed beyond the prescribed period, it was barred by limitation. The assessee explained that the delay of 96 days in filing the appeal occurred because the person responsible for filing the appeal was on leave owing to his daughter’s marriage and the appeal was filed immediately after he became aware of the position. The Tribunal held that the explanation constituted sufficient cause and, adopting a liberal approach, condoned the delay in the interest of justice  (AY. 2017-18).