PCIT's Attempt to Revise Accepted Tax Loss Deemed Inappropriate Due to Time Limit Violation u/s 263.

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....Revision u/s 263 to set aside an order passed u/s. 154 - Once a loss has been disclosed in the income tax return, and such a loss has not been disturbed in the scrutiny assessment proceedings, such a loss is treated to have been accepted, and quantification thereof cannot be disturbed. What the learned PCIT has done is to disturb this quantum of loss, but then that could have been done within two years from the end of the financial year in which the related scrutiny assessment order was passed. - AT....