Section 263 revision cannot reopen a concluded assessment issue outside the scope of reassessment and time limits.

Section 263 revision could not be sustained where the alleged error concerned stamp-duty valuation under section 50C, an issue already examined in the original scrutiny assessment under section 143(3). The reassessment under section 147 read with section 144B was initiated on a different ground, namely the applicability of section 56(2)(vii)(b) to newly acquired property, so the Commissioner could not use revisional power to reopen a concluded matter outside the scope of the reassessment. As the original order was already time-barred for revision and the reassessment order was not shown to be erroneous on its own basis, the revisional order was quashed.

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Issues: Whether the revisionary order under section 263 could be sustained when the alleged error related to an issue already examined in the original assessment and not arising from the reassessment order.

Analysis: The reassessment under section 147 read with section 144B was initiated for a different matter, namely the applicability of section 56(2)(vii)(b) to the newly acquired property. The Commissioner, however, invoked section 263 on the footing that the enhanced stamp-duty value of the sold properties ought to have been considered under section 50C. That issue had already been dealt with in the original scrutiny assessment under section 143(3). The revisional jurisdiction could not be used to revisit a matter concluded in the earlier assessment, especially when the period for revising that original order had already expired. The reassessment order itself was not shown to be erroneous on the ground on which it was made.

Conclusion: The revision under section 263 was not sustainable and was rightly quashed.

Ratio Decidendi: Section 263 cannot be invoked to revise a reassessment order on a ground that was already concluded in the original assessment and is outside the scope of the reassessment, particularly where revision of the original order is time-barred.

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