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When it comes to period of limitation it is the order specific to the matter under revision. The limitation would not extend further with any reassessment m, rectification etc further as stated by the Court in[2022] 441 ITR 689 (Mad). In this case the original assessment was completed on December 28, 2006 and reassessment was completed on December 30, 2011. The revision was attempted vide order dated 26 March 2014 in respect of an issue, which was not subject matter of reassessment with the claim that 2 years limitation shall end on March 31 2014 and not on March 31 2009.
unhesitatingly it is held that the proceedings under section 263 of the Act were initiated well beyond the due date, exercise of such power is thus held to be without jurisdiction and barred by limitation.

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