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TMI Blog2013 (11) TMI 1059X X X X Extracts X X X X X X X X Extracts X X X X ..... .10.2012 declaring the Net taxable income as nil and book profit computed under Section 115TB amounting to Rs. 17,66,14,319/-. The returns came to be processed under Section 143(1) of the Income Tax Act (hereinafter referred to as the Act) on 10.08.2006. Thereafter, a revised return of income came to be filed on 23.03.2007 declaring gross total income under the normal provisions of the Act and cla ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l income of Rs. 27,28,51,217/- and accordingly the total income under the normal provisions of the Act, after set off and other deductions was arrived at as nil. 3. Thereafter, invoking suo motu jurisdiction under Section 263 of the Act, Commissioner of Income Tax, Cochin issued an order dated 18.03.2011 holding that order of the Assessing Officer giving effect to the order of the CIT(Appeals-II) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Revenue contending that initiation of proceedings under Section 263 of the Act dated 18.03.2001 is in respect of the orders of the CIT(Appeals) and therefore, question of limitation would not arise in the case on hand. 5. It is pertinent to note that the assessee went before the First Appellate authority against the initial assessment order not with regard to the nature of computation that is b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... it computation accepted by the assessing authority, it ought to be from 28.12.2007 and not with reference to First Appellate Authority's order which was nothing to do with acceptance of book profit computation adopted by the assessee. 7. For the above said reasons, we are of the opinion, the Tribunal was justified in opining that the Administrative Commissioner was not justified so far as initiat ..... X X X X Extracts X X X X X X X X Extracts X X X X
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