Section 263 could be invoked if both the ingredients are satisfied

Brief of the Case

The Hon’ble High Court in this case held that whenever, the Commissioner is satisfied that order of AO is erroneous as well as prejudicial to the interests of Revenue, then the Commissioner could invoke Revisionary Powers u/s 263.

Facts of the Case

The assessee is a Proprietor of a Rice Mill, and he completed the construction of rice mill by March 1999. He filed return of income for the as

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