Revision u/s 263 not allowed on matters which already enquired and replied in original assessment

Brief of the Case ITAT Ahmadabad held In the case of Adani Port & Special Economic Zone Ltd. vs. ACIT that two circumstances must exist to enable the Commissioner to exercise power of revision u/s 263, namely (i) the order is erroneous (ii) by virtue of being erroneous prejudice has been caused to the interests of the Revenue. In the light of the requirement of provisions of Section 263 and the various decisions of high courts, in the present case, it is seen that Section 263 has been invoked on 3 grounds. On these 3 issues, it is seen that during the course of assessment proceedings, A.O ...