The Revenue made a protective assessment in the assessee’s case while making a substantive assessment in the hands of another person. Subsequently, the substantive assessment was confirmed in appeal. The Tribunal held that once the substantive assessment had attained finality in the other person’s case, the protective assessment against the assessee could not survive. Consequently, the revision proceedings initiated under section 263 were without jurisdiction and liable to be quashed. The Tribunal found that the Commissioner had passed the revisionary order without dealing with the detailed submissions made by the assessee. Such non-consideration amounted to a serious violation of the principles of natural justice. Accordingly, the order passed under section 263 was set aside (AY. 2013-14).