Case Law Analysis
|Income Tax Appellate Tribunal
Section 263 IT Act | Limitation Period for Revisionary Powers Runs from Original Assessment, Not Reassessment Order : ITAT Delhi
The ITAT Delhi holds that the two-year limitation under Section 263 begins from the date of the original assessment order, not the subsequent reassessment, when the revision challenges errors inherent in the initial assessment. This clarifies a critical procedural trap for tax authorities and protects assessees from delayed revisionary attacks on stale assessments, directly impacting how revenue departments strategize revisionary proceedings.