CIT Oversteps: Revises Reassessment Order Beyond Jurisdiction, Invalidating Action Favoring Assessee Under Sec. 263.

u/s 263, the AO had not made any addition regarding cash deposits in the assessee company's bank account and unsecured loan received during the year under consideration, which was the basis for reopening the case u/s 147. The AO was divested of jurisdiction to make further independent additions/disallowances. The CIT could not hold the reassessment order erroneous for failing to verify independent issues. The CIT's jurisdiction u/s 263 is limited to the subject matter of reassessment. If distinct, the limitation period for section 263 starts from the original assessment order date. The CIT exceeded jurisdiction by revising the order regarding share capital/premium and unsecured loans, as these did not form the reassessment subject matter u/s 147. Hence, the CIT's revision order u/s 263 was struck down, favoring the assessee. .....

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