Tribunal held  even though the Assessing Officer did not discuss the issue of taxability of receipt of Rs. 9.14 crores in the assessment order, he did make inquiry on it, sought clarifications from the assessee, applied his mind and got satisfied about its non-taxability on the basis of the view taken by him in the assessment order under section 143(3) for the immediately preceding assessment year, namely, 2010-11, when the order for the immediately preceding assessment year passed under section 143(3) treating the amount of headquarters fees as not chargeable to tax was available on record before the Assessing Officer, he was well justified in adopting such a possible view on the non-taxability of the amount for the year under consideration as well. Such an assessment order could not be construed as erroneous as well as prejudicial to the interests of the Revenue for not having included Rs. 9.14 crores in the total income, when the Department itself accepted the receipt as not chargeable to tax for the immediately preceding assessment year. None of the four clauses of Explanation 2 applied to the case under consideration. The revisionary power, even under the enlarged scope of Explanation 2, was not legally exercisable.  Prospective provisions, inserted from a specific date in the midst of a financial year, falling within the realm of procedural aspects of the assessment or not directly effecting the shrinking or swelling of total income, are ordinarily construed as prospective qua the proceedings and not qua the assessment year. As Explanation 2 to section 263(1) of the Income-tax Act, 1961, inserted with effect from June 1, 2015, is an enabling provision empowering the Commissioner to deem the assessment order erroneous and prejudicial to the interests of the Revenue in the four situations as set out in clauses (a) to (d) therein, it will have its application qua the revision proceedings and not the assessment year following such date. (AY. 2011-12)