COMMR.OF INCOME TAX,CHENNAI vs M/S ALAGENDRAN FINANCE LTD.

The Supreme Court addressed the issue of limitation under Section 263 of the Income Tax Act, 1961, determining that the date of the original assessment order, rather than the reassessment order, should be considered for computing the limitation period. The Court held that the Commissioner of Income Tax's invocation of revisional jurisdiction was barred by limitation as the reassessment proceedings were initiated beyond the prescribed period. Consequently, the Court upheld the decision of the Income Tax Appellate Tribunal, which ruled in favor of the assessee, affirming that the reassessment was invalid due to limitation issues.