The AO passed a rectification order stating that section 115QA(1) was not applicable before 1-6-2016. Subsequently, the Principal Commissioner of Income Tax (PCIT) passed an order under section 263 on 10-6-2020, treating the rectification order as erroneous and prejudicial to the interest of the Revenue. The Tribunal, on appeal, held that the Commissioner could exercise jurisdiction only until 31-03-2019. Considering that the PCIT exercised jurisdiction on 10-06-2020 against an order dated 28-12-2017, the revision order was time-barred. Moreover, the Tribunal noted that section 115QA was not applicable before 1-6-2016, concluding that the PCIT was not justified in invoking section 263. The High Court upheld the Tribunal’s findings on the issue of limitation and held that “buy back” means the purchase of a company’s own shares under section 77 of the Companies Act. As the buy-back was pursuant to an order of the Company Law Board under section 402 of the Companies Act, it was not included in section 115QA. Therefore, the PCIT was not justified in invoking the provisions of section 263. (AY. 2015-16)