Limitation u/s 263 of Ties to Original Assessment Order when Reassessment Order is Distinct and Different: Rajasthan HC

The Rajasthan High Court ruled that the limitation period under Section 263 of the Income Tax Act is tied to the original assessment order when the reassessment order is distinct and different. The court clarified that the revisionary authority cannot extend the limitation period by reopening reassessment proceedings. This decision sets a precedent for the interpretation of limitation periods in tax cases, potentially affecting future revisions by tax authorities.