Commissioner Cannot Reopen Completed Tax Assessments Without Just Cause Under Explanation-2 to Section 263 of the Income Tax Act.

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....Revision u/s 263 - Explanation-2 to section 263 of the Act does not give a uncontrolled & unbridled power to the revisional Commissioner to reopen a completed assessment to conduct further enquiries to verify and find out whether order passed is in fact erroneous or not. The facts explained on behalf of the assessee gives an infallible impression that the course adopted by the assessee in treating the gains as capital gains chargeable under section 45 of the Act and endorsed by the A.O. to be plausible. - AT....