Where revisionary proceedings were invoked on grounds that the assessee wrongly adjusted LTCL twice once with LTCG and then again with STCG since the same was a case of bona fide mistake committed by the assessee purely based on verifiable facts which had no bearing on income-tax liability for the year under the consideration and effect was on availability of MAT credit in the subsequent year for which assessee submitted to make a course correction, revisionary proceedings under section 263 would not be justifiable

Revision of an order under section 263 presupposes the existence of an order since levy of interest under section 115P and any liability of DDT under section 115-O gets fastened on the assessee by provisions contained under Chapter XIID and did not form part of assessment order under section 143(3), Principal Commissioner could not have invoked revisionary proceedings to direct AO to impose DDT liability in reference to assessment order passed under section 143(3) (AY. 2018-19)