Assessee’s assessment order u/s 147 was subject to 263 proceedings . Subsequently search took place in assessee group company and assessment u/s 153A concluded without any adverse inference touching upon the issues which were subject matter of earlier 263 proceedings , although the AO was unaware of any such 263 proceedings. The assessment u/s 153A had attained finality & no 263 proceedings initiated by Department against such order . The earlier 263 order was challenged before ITAT which set aside the matter back to CIT for giving opportunity. Despite the CIT informed about subsequent 153A order which has merged & all earlier proceedings abated , still the PCIT had passed fresh order u/s 263 giving directions to AO to make enquiries afresh for a case related to 13 years back . This 263 order needs to be challenged before ITAT since the matter had already attained finality and there has to be an end to litigation