Commissioner Of Income Tax, Chennai vs M/S. Alagendran Finance Ltd

The Supreme Court addressed the interpretation of Sub-section (2) of Section 263 of the Income Tax Act, 1961, determining that the date of the original assessment order, rather than the reassessment order, is critical for computing the limitation period for invoking revisional jurisdiction. The Court held that the Income Tax Appellate Tribunal's finding that the proceedings under Section 263 were barred by limitation was correct, thereby upholding the Tribunal's decision. Consequently, the appeal was dismissed, affirming the Tribunal's ruling on the limitation issue.