Revision under section 263 must be initiated within two years...

Revision under section 263 must be initiated within two years from the end of the financial year in which the assessment order was passed. The limitation expired before the first revisionary notice and order were issued, rendering the revisionary order time-barred and liable to be quashed. Independently, revision of the assessment treating integrated hardware systems with embedded software as non-royalty was unwarranted because the Assessing Officer had examined the agreements, copyright rights, software and services, and the India-United Kingdom tax treaty. Consistent earlier decisions and the Supreme Court's Engineering Analysis ruling supported the non-royalty treatment, so the assessment order was not erroneous or prejudicial to Revenue interests.