Allowing the petitions, the Court held that ; after the Assessing Officer passed the order of assessment in the case of the partner, the firm had filed a revised computation of income before the Assessing Officer before whom the assessment of the firm was still pending. To that extent, the view of the Commissioner that such expenditure would not be allowed in the hands of the firm also, could not be accepted. That the non-filing of the revised return by the firm could not have been a ground for rejection of the claim. Even if the powers of the Assessing Officer could have been restricted in the absence of a revised return, the Commissioner could have examined the issue and made further inquiries, if it was needed. Section 264 used the expression “any order” which implied that the section did not limit the revisional power of the Commissioner to correct the errors committed by the subordinate authorities but could also be exercised where errors were committed by the assessee. The Act proceeded on the fundamental principle of taxing real income. The accounts could not change taxability or non-taxability of a certain receipt which depended on the nature of the receipt and the legal principles applicable. ( AY. 2012-13)