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TMI Blog2024 (2) TMI 1381X X X X Extracts X X X X X X X X Extracts X X X X ..... d of limitation for passing u/s 263 has to be reckoned from the date of original assessment order or from the date of reassessment order? - HELD THAT:- As decided in Industrial Development Bank of India Ltd. [ 2023 (6) TMI 1047 - SUPREME COURT ] once an Order of Assessment is re-opened, the previous order of assessment will be held to be set aside and the whole proceedings would start afresh but t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... date of original assessment order and not from the date of reassessment order. Decided in favour of assessee. X X X X Extracts X X X X X X X X Extracts X X X X ..... ith respect to the issues which were not covered in the re-assessment proceedings. Therefore, the issues before the Commissioner while exercising the powers under Section 263 of the Act relate back to the original Assessment Order and, therefore, the limitation would start from the original Assessment Order and not from the Reassessment Order. We are fortified with our view by the decision of this ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... distinct and different, in that case the relevant date for the purpose of determination of period of limitation for exercising powers under Section 263 of the Act would be the date of the original Assessment Order." 4. In view of the aforesaid authoritative pronouncement, it is clear that for the purposes of exercising powers under Section 263 of Income Tax Act, 1961, the period of limitation fo ..... X X X X Extracts X X X X X X X X Extracts X X X X
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