Reassessment Order u/ss 143(3) & 147 Barred by Limitation Due to Delay Beyond Two-Year Period u/s 263(2.

Revision u/s 263 - period of limitation - the case was re-assessed u/s. 143(3) r.w.s. 147 - the case of the assessee was again reopened and the assessment u/s. 143(3) r.w.s. 147 of the Act was completed 22.12.2017. No doubt, original assessment order is liable to be considered to reckon the limitation and accordingly passing the order on 21.03.2021 u/s. 263(2) of the Act is clearly barred by limitation which is beyond two years. - AT .....

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