https://www.taxtmi.com/caselaws?id=457939 Revisional jurisdiction under Section 263 could not be used to bring in an issue that lay outside the reassessment initiated under Section 147 and had not been examined by the assessing officer. Because the loss or expenditure on the newly undertaken software product development project was not part of the reassessment proceedings, the Commissioner had no basis to revise that matter. The invocation of Section 263 on that issue was therefore not justified, and the substantial question of law was answered against the revenue. en-us Fri, 17 Feb 2023 00:00:00 +0530 Mon, 30 Sep 2024 20:24:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=457939 Revisional jurisdiction under Section 263 could not be used to bring in an issue that lay outside the reassessment initiated under Section 147 and had not been examined by the assessing officer. Because the loss or expenditure on the newly undertaken software product development project was not part of the reassessment proceedings, the Commissioner had no basis to revise that matter. The invocation of Section 263 on that issue was therefore not justified, and the substantial question of law was answered against the revenue. Case-Laws Income Tax Fri, 17 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=457939