The Tribunal held that the insertion of Explanation 2 in section 263 by the Finance Act, 2015 with effect from June 1, 2015 does not ipso facto mean that every regular assessment could be revised even in cases where the action of the Assessing Officer satisfies the normal “prudence” test in scrutiny. The Principal Commissioner’s revision directions qua the issue of section 115JB minimum alternate tax computation of prior period income was not substantive. As regards excise duty  Section 43B made it clear such a deduction of excise duty under sub-section (1) thereof is allowable only on actual payment irrespective of the previous year in which the liability to pay it as arose to the assessee according to the method of accounting regularly employed. The Revenue’s stand questioning the liability of the assessee to excise duty whether for factual reverification or on legality, was rejected on this sole ground.( AY.2014-15)