#section 263
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PCIT cannot substitute his view in exercise of revisional jurisdiction u/s. 263
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Delay of 988 days cannot be condoned on the basis of vague reason
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Revisionary action u/s 263 on mere change of opinion is unsustainable
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Fresh assessment order in pursuance of order u/s 254, 263 or 264 should be made within 9 months
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Manual order without containing DIN is invalid & deemed as if never been issued
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Non-discussion of issue in assessment order doesn’t make it erroneous & prejudicial to interest of revenue
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Invocation of revisional jurisdiction u/s 263 on mere conjectures, suspicions and surmises, is impermissible
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ITAT quashes section 263 revision order passed on a deceased assessee
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Section 263 notice issued to a person after his death is invalid
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Initiation of revisionary proceeding u/s 263 on fishing and roving enquiry is unjustified
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Section 263 invocable as non-verification of trade discount vis-à-vis TDS makes assessment order erroneous
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Revisionary power u/s 263 not invocable as facts already examined by AO
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Revision u/s 263 without satisfying twin conditions is unsustainable
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