Section 263 revision by Income Tax Commissioner invalid without supporting evidence; fishing inquiries not allowed.

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....Revision u/s 263 by CIT - If there are no materials on record on the basis of which it can be said that the Commissioner acting in a reasonable manner could have come to such a conclusion, the very initiation of proceedings by him will be illegal and without jurisdiction. TCommissioner cannot initiate proceedings with a view to starting fishing and roving enquiries in matters or orders which are already concluded. - AT....