Dismissing the appeal of the Revenue the Court held that the conclusion of the Tribunal, to the extent, that the Commissioner could not have unilaterally directed the Assessing Officer to add back the sum paid towards the import of raw materials by holding that it was disallowable as expenditure could not have been issued under section 263 without the Assessing Officer re-examining the issue was beyond the jurisdiction of the Commissioner, did not suffer from  any legal infirmity. Order of Tribunal is affirmed. No substantial  question of law. (AY. 2007-08)