Assessing Officer reopened the assessment of the assessee on the basis of a search in one group and had passed an assessment order under section 143(3) read with section 147, making additions under section 68. Thereafter, the Pr. Commissioner had passed an order under section 263 on the ground that the Assessing Officer failed to conduct necessary inquiries and verification in respect of disallowance under section 14A read with rule 8D. On writ, the Court held that since the Assessing Officer had made inquiries with regard to disallowance under section 14A read with rule 8D during the course of regular assessment, therefore, the Assessing Officer, while carrying out re-assessment proceedings, could not have again made any inquiry for said issue. Pr. Commissioner could not have assumed jurisdiction by invoking explanation (ii) of section 263 as issue of disallowance under section 14A was already subject matter of inquiry and therefore, issue as to whether inquiry was insufficient or not, could not have been subject matter of revisional proceedings as it would amount to mere change of opinion. Accordingly, the revision order passed by Pr. Commissioner under section 263 being unsustainable was quashed and set aside.  (AY. 2012-13, 2014-15)