In assessment proceedings pursuant to order under section 263 assessee cannot seek to show that there was some other benefit in favour of revenue which was prejudicial to interest of assessee

Only in the cases where the assessment order is erroneous and prejudicial to the interests of the revenue and not prejudicial to the interest of the assessee can be reopened under section 263 and the assessee is not eligible to claim any new benefit in the assessment proceedings pursuant to section 263. RELEVANT PARAGRAPH FACTS The assessee, a public limited company, filed its return of income for the assessment year 2000-01 on 30-11-2000 admitting an income of Rs.1,04,25,160 and the same was processed u/s 143(1) on 15-3-2001. The assessee had also filed revised return of income on 28-3-2002 a...