CIT's Section 263 Revision Valid for Errors in Fact or Law, Not All AO Revenue Losses Qualify.

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....Revision u/s 263 by CIT - An incorrect assumption of the fact or an incorrect application of law will satisfy the requirement of the order being erroneous. The phrase 'prejudicial to the interest of the Revenue has to be read in conjunction with an erroneous order passed by the AO. Every loss of revenue as a consequence of the order of the AO cannot be treated as prejudicial to the interest of the Revenue - AT....