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AO's Enquiry Validates, CIT's Section 263 Re-evaluation Blocked Due to Prior Application of Mind.

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Full Text of the Document

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....Revision u/s 263 - AO actually carried out an enquiry after the reopening of the proceedings and that once there was an application of mind, on the part of the AO, it was not open to the Commissioner to invoke the jurisdiction u/s 263 - CIT by invoking Section 263 only attempted to re-appreciate the facts which is not permissible....