Held that order passed by the Assessing Officer cannot be revised on an issue which was not taken up in limited scrutiny on the ground that what Assessing Officer could not have done directly the Commissioner cannot invoke revision jurisdiction. Relied on CBDT instruction No. 2/2014 dt. 26-9 2014. Referred, Sanjib Kumar Khemka (ITA No. 1361/kol/2016 dt 2-6-2017 (AY. 2011-12), Chengmari Tea Co Ltd (ITA No. 812/Kol/2019 dt 31-1-2020. (AY. 2014-15)
Spotlight Vanijya Ltd. v. PCIT (2021) BCAJ-June-P. 27 (Kol.)(Trib.)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Limited scrutiny-Order passed by the Assessing Officer cannot be revised on an issue which was not taken up in limited scrutiny. [S. 143(2)]