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2023 (7) TMI 1259 - AT - Income TaxRevision u/s 263 - Period of limitation of two years - HELD THAT:- When the claim of interest on income tax was not a subject matter of subsequent order passed by the Ld. AO u/s 143(3) r.w.s. 263 of the Act then the limitation period of two years as prescribed under subsection (2) of section 263 of the Act would reckon from the date of the first assessment and not from the second assessment. Accordingly, we are of the considered view that the impugned revision order passed by the ld. Pr. CIT dated 24.02.2021 is beyond the period of limitation of two years provided under sub-section (2) of section 263 of the Act and consequently, the impugned order is not sustainable in law and liable to be quashed. Decided in favour of assessee.
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