Use of "Seems" in Show Cause Notice Suggests Uncertainty, Section 263 Order Set Aside for Lack of Conviction.

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....Revision u/s 263 - Use of word "seems" by the CIT while recording reasons - It seems that, Assessment order passed by the A.O. in this case is erroneous and prejudicial to the interests of the Revenue.” The Ld. Pr. CIT has referred the word “seems” twice in para 6 of the above show cause notice. It would, therefore, show that even he was not sure whether it is a fit case of invoking jurisdiction u/s 263 - order set aside - AT....