Revisiting the Scope of 'Record' u/s 263: Embracing Subsequent Records

Revisional power: Commissioner may consider subsequent records available at time of examination in tax proceedings.

The Court construed the Commissioner's revisional power to permit consideration of all materials relating to the proceeding that are available at the time of his examination, including documents and valuation reports that came on the file after the assessment order; the Explanation to the provision was read as clarificatory, giving an inclusive meaning to 'record' rather than restricting it to what the Assessing Officer had when passing the assessment.