AdvertisementCIT Vs Industrial Development Bank of India Ltd (Supreme Court of India) The Supreme Court considered the Revenue’s appeal against the Bombay High Court judgment dated 07.05.2009, which had dismissed the Revenue’s appeal and affirmed the ITAT’s order holding that the Commissioner’s order under Section 263 of the Income-tax Act, 1961 was barred by limitation. The question before the Court was whether the limitation period for passing an order under Section 263 should be reckoned from the date of the original assessment order or from the date of the reassessment order.