CIT's Section 263 Findings Flawed: Errors Lead to Miscarriage of Justice, Burden Shifted to Assessing Officer.

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....Revision u/s 263 - The findings of CIT suffer from apparent error and incompleteness. CIT has summarily set aside the re-assessment order and shifted the responsibility on the AO to examine or verify the facts. The opportunity contemplated under Section 263 is thus rendered illusory and merely an empty formality resulting in miscarriage of justice in contravention of express intendment of provision of Section 263. - AT....