Principal CIT Can't Revise u/s 147/143(3) for Unexamined Issues; Must Use Section 143(1) Instead.

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....Revision u/s 263 - as per CIT assessment framed by the AO under section 143(3) read with section 147 of the Act as erroneous insofar prejudicial to the interest of Revenue - the learned principal CIT cannot held the order under section 147 r.w.s. 143(3) for non-enquiry of share capital which was not the part of the proceeding. If he wanted to do so then he has to revise the order under section 143(1) of the Act as the case may be. - AT....