Date of passing of order to be considered and not its receipt by assessee for counting period of limitation u/s 263: SC

INCOME TAX : Where once it was established that order under section 263 was made/passed within period of two years from end of relevant financial year in which order sought to be revised was passed, such order would be within period of limitation prescribed under section 263(2) and receipt of order by assessee would have no relevance for purpose of counting period of limitation under section 263

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