S. 263 : Commissioner-Revision of orders prejudicial to revenue–Merger–Limitation-Merger of assessment order in appellate order—Revision is bad in law- Order of assessment in 2005— Revision in 2009—Barred by limitation-Question regarding limitation can be raised for first time Before High Court. [S.80IB, 153A, 251, 260A]

S. 263 : Commissioner-Revision of orders prejudicial to revenue–Survey – Admission of additional income-Assessment order was passed without enquiry—Revision is held to be valid-Central Board of Direct Taxes is directed to issue necessary instructions to all the Assessing Officers in cases of search and seizure or where survey operations have been carried out by the Department and surrender made or concealed income detected, to ensure proper scrutiny of such cases and discuss reasons for rejecting or accepting the books of account of the assessee and not to merely record in slipshod or cursory manner that “the books of account produced and test checked” as done by the Assessing Officer. [S.119, 132, 133A]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Assessment after detailed enquiry-Income from house property– Income from other sources- Notice of revision is not valid. [S. 143(3)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue -Merger –Bogus purchases-Appeal regarding particular issue was pending before CIT (A) and decided when the reply to show cause notice was pending-Commissioner cannot revise order with regard to that issue. [S. 251]

S. 263 : Commissioner-Revision of orders prejudicial to revenue- Receipts on account of non-competition fee and assignment of trademark was held to be not taxable by the Assessing Officer- Taking a plausible view- Revision is held to be not valid. [S.55(2)(a)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue -Merger- Commissioner has no jurisdiction to consider matters considered by Commissioner (Appeals) in Appeal. [S. 2(15), 10(20), 11, 251]

S. 263 : Commissioner – Revision of orders prejudicial to revenue –Share capital at high premium- Directions and guidelines to Assessing Officer to inquire in regard to infusion of share capital at high premium—Revision order is valid-Application for adjournment of hearing was submitted two days after scheduled date of hearing—Principles of natural justice is not violated. [S.68, 119, Code of Civil Procedure 19089 O.IX R. 13]

S. 260A : Appeal – High Court – Question regarding limitation can be raised for first time Before High Court –Revision was held to be bad in law. [S. 80IB,153A, 251, 260A, 263]

S. 254(1) : Appellate Tribunal–Duties–Bogus purchases–Direction of CIT(A) was set aside by Tribunal-Recording of fact by Assessing Officer that supplier did not file return—Failure by Tribunal as final fact finding authority to consider facts—Matter remanded to Tribunal for fresh disposal. [S. 37(1), 133(6), 251]

S. 253 : Appellate Tribunal-Territorial jurisdiction-Assessee situated at Moga within jurisdiction of Amritsar Bench-Order passed by Appellate Tribunal at Chandigarh without territorial jurisdiction-Order is null and void-Matter to be sent to Amritsar Bench for disposal. [S. 254(1)]