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2023 (3) TMI 1543 - HC - Income TaxRevision u/s 263 beyond period of limitation - HELD THAT - Any order u/s 263 of the Act can be passed only within two years from the date of the order sought to be revised. In the instant case admittedly the order sought to be revised is dated 31.03.2017 and the impugned notice is issued on 01.02.2023 and the proceedings contemplated as per the notice is liable to be set aside on the ground of limitation.
The High Court of Karnataka ruled in favor of the petitioner, a Private Limited Company, in a case regarding income tax assessment for the year 2002-03. The court set aside the notice issued by the respondent under Section 263 of the Income Tax Act on the grounds of limitation, as the notice was issued after the two-year limit from the date of the order sought to be revised.
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