2024 (2) TMI 1381

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..... stice Bhuwan Goyal For the Petitioner : Mr. Sanjay Jhanwar, Sr. Adv. Assisted by Mr. Aryan Singh. For the Respondent : Mr. Shantanu Sharma with Ms. Bhawna Laddha. ORDER 1. A prayer for early listing has been made on the ground that the issue raised in this writ petition is now squarely covered by the decision of the Supreme Court in the case of Commissioner of Income Tax Vs. Industrial Develop .....

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..... 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 Court in the case of Commissioner of Income Tax, Chennai vs. Alagendran Finance Ltd. (2007) 7 SCC 215. As observed and held by this Court in the aforesaid decision, once an Order of Assessment is .....

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..... 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 for passing the order has to be reckoned from the date of original assessment order and not from the date of reassessment order. 5. The aforesaid legal position is not disputed by learned counsel fo .....

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