S. 263 Commissioner cannot revise a order when AO took a possible view

CIT revised the order u/s 263 to include the sum of Rs. 1,75,32,600/- in the total income of the assessee under Sec.41(1) of the Income Tax Act on the ground that there had been a complete cessation of liability in regard to this amount in the previous year relevant to the assessment year 1982-83- ITAT confirmed the order – held that – when the Assessing Officer took a possible view, while passing an order of assessment, the Commissioner exceeded his jurisdiction in seeking recourse to his power under Section 263.

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