Re-assessment proceedings were initiated against assessee on ground that assessee had received capitation fees or development fund in cash or kind which had not been disclosed in return, resulting in escapement of income. Re-assessment order was passed treating corpus donation received by assessee as general donation to trust and thereby re-computing exemption available under sections 11 and 12.  Commissioner passed revision order on 21-3-2024 against said re-assessment order dated 25-3-2022 on ground that Assessing Officer had not verified accumulation and application for year under consideration for purpose of object of trust for which amount was set apart. On appeal the Tribunal held that  issue dealt by Commissioner in revision proceedings was altogether unrelated and different in character from issue dealt by Assessing Officer in re-assessment proceedings. The  issue raised by Commissioner to invoke revisionary proceedings had to necessarily relate to intimation passed under section 143(1).  On facts the revision order passed by Commissioner  is  beyond  period of  two years  hence the order is  barred by limitation  hence quashed. (AY. 2016-17)