CIT cannot use Section 263 to override the Assessing Officer's decision based on differing opinions about the material assessed.

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....Revision u/s 263 by CIT - receipt of share premium - the power of revision u/s 263 does not allow for supplanting or substituting the view of the Assessing Officer. The appreciation of material placed before the Assessing Officer is exclusively within his domain which cannot be interdicted by a superior officer while exercising powers u/s 263 of the Act on the ground that if he had appraised the said material, he would have come to a different conclusion - AT....