CIT Cannot Use Section 263 to Revise Assessments for Reasons Not Covered in Reopening Once Section 143(3) Period Ends.

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....Revision u/s 263 - order passed u/s 143(3) r.w.s. 147 wherein the assessment were re-opened on specific reasons recorded for re-opening and addition made - CIT is precluded from exercise of jurisdiction u/s 263 on a ground which is not covered by the reasons during the reopening of the assessment since the time for completing the assessment u/s 143(3) had expired....