When AO has conducted an enquiry and taken a possible view u/s 263, then CIT cannot take a different view

The facts in, brief, are that the assessee is a company carrying business of investment and trading in shares and securities. A search and seizure action took place in the premises of the assessee on two occasions, firstly, on 25/06/03 and secondly on 28/10/04. As a result, assessment orders u/s 143(3) r.w.s 153A were also passed on two occasions, firstly on 27/02/06 and secondly on 28/12/2006, accepting the returned income as assessed income at Rs. 3,42,430/- on both the occasions. Subsequently, a proposal for reopening the impugned assessments u/s 263 was submitted by the AO to the CIT. Acco...