Day Jobbing Trades Not Speculative; Consistency Rule Applied, Section 263 Orders Set Aside, Audit Objections Addressed.

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....Revision u/s 263 - speculative transaction or not - majority of trades undertaken through day jobbing in which sale and purchase of scrips on same day are matched without taking the delivery of the scrips - if rule of consistency is applicable on the same facts and circumstances in these years, then merely changing the head of income from business to speculation, then it cannot be held that the assessment order is erroneous and prejudicial to the interest of revenue. More so, here in this case, section 263 has been done only on the basis of audit objection which was only for the purpose of verification and which has already been examined by the AO during the course of assessment proceedings. Accordingly, the impugned orders u/s. 263 are set aside - AT....