During scrutiny, Assessing Officer held that services provided by petitioner were to be treated as consultancy services and would be taxable in India. Petitioner preferred an appeal before Commissioner (Appeals) against final assessment order.  Subsequently, Commissioner invoked section 263 to revise assessment order on ground that Assessing Officer failed to note that since petitioner had a PE in India it could be taxed as per provisions of MAT under section 115JB. The petitioner challenged the revision order by filling  the writ petition on the ground that order is without jurisdiction. Dismissing the petition the Court held that scope of appeal before Commissioner (Appeals) was confined to taxability of receipts towards services rendered by petitioner, thus, there was no embargo under section 263 for Commissioner to pass revisionary order as matter was not considered in appeal. Court also held thatrevisionary order could not be said to be without jurisdiction merely because document identification number (DIN) of  order was intimated one day after said order was passed. (AY. 2015-16)