PCIT's Section 263 revision on late PF, ESIC contributions invalid; AO actions must align with CBDT circular, not High Court.

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....Revision u/s 263 - belated employee’s contribution to PF and ESIC funds - AO did not follow the CBDT circular but followed the HC decision - The CIT in exercise the powers vested u/s 263 of the Act cannot do something, what the Assessing Officer himself cannot do. Thus, the very premises on which revision was sought to be made by ld. PCIT had failed, and resultant order has no legs to stand. - AT....