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2021 (12) TMI 262 - CALCUTTA HIGH COURTRevision u/s 263 by CIT - justifying the legislative intent of Section 115 JB and 115 JAA - HELD THAT:- Tribunal took note of the decision of the Hon’ble Supreme Court in CIT vs. Alagendran Finance Limited [2007 (7) TMI 304 - SUPREME COURT] and held that the order passed by the CIT u/s 263(2) is hopelessly barred by limitation. The Tribunal rightly held that the period of limitation for the assessment year 2007-08 has to be reckoned from the date of the order passed by the AO under Section 143(3) read with Section 263 i.e. 8th December, 2011 and not from the date of the order passed by the AO under Section 143(3) read with Section 263 and 251 dated 29th November, 2012. Thus, we find that the Tribunal rightly allowed by the appeal filed by the assessee.
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