In Brief
The Commissioner of Income Tax issued a revision order under Section 263 on 26 March 2012 and dispatched it on 28 March 2012, seeking to revise an assessment order dated 30 December 2010 for AY 2008-09. The assessee received notice only on 6 August 2012 and challenged the revision as time-barred under Section 263(2), which prescribes a two-year limit from the end of the relevant financial year (31 March 2012). The High Court upheld the assessee's contention, treating the date of service/receipt as relevant. The Supreme Court allowed the revenue's appeal, holding that the statutory period is calculated from when the order is 'made' (26 March 2012), not when the assessee receives it (29 November 2012), and the order was therefore within limitation."
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