Jurisdictional defect in section 263 revision defeated later notification-based authority and restored the original assessment order.

Revision under section 263 failed because the Commissioner lacked jurisdiction on the relevant date. The assessment order under section 143(3) had been passed before the jurisdictional notification took effect on 15.11.2014, so the later jurisdictional change could not validate the revisional action. Objections based on the assessee's participation in later proceedings and section 292BB were rejected because they did not cure the foundational absence of jurisdiction for the earlier revision order. The revisional order was quashed and the assessment order was restored.

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Issues: Whether the Commissioner had jurisdiction to invoke revisionary powers under section 263 of the Income-tax Act, 1961 when, on the date of the assessment order, the assessee and the assessing officer fell within a different jurisdiction and the jurisdictional notification took effect only later.

Analysis: The dispute turned on the date from which the jurisdictional notification operated. The assessment order under section 143(3) was passed before the change in jurisdiction notified on 15.11.2014. The objections based on participation in later proceedings and section 292BB were not accepted as curing the foundational absence of jurisdiction for the earlier revisionary action. Since the revisional order was made by an authority that did not have jurisdiction on the relevant date, the assumption of power under section 263 could not stand.

Conclusion: The revision order under section 263 was held to be jurisdiction and was quashed, with the assessment order under section 143(3) restored.

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