On appeal before the Tribunal the question was whether there can be no revision because the power under section 263 can be invoked only in cases of lack of inquiry and not for conducting inadequate inquiry. The Tribunal held that the Commissioner cannot initiate proceedings with a view to start fishing and roving enquiries in matters or orders which are already concluded. Such action will be against the well accepted policy of law that there must be a point of finality in all legal proceedings, that stale issues should not be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest judicial and quasi-judicial controversies as it must in other spheres of human activity. Therefore, orders under section 263 cannot be sustained as the conditions for exercise of jurisdiction under the said provisions are absent in the instant case. Therefore, the impugned orders under section 263 in these appeals are quashed.