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Section 263 provide powers to the Commissioner to modify, enhance, cancel or direct fresh assessment in a situation where he considers that the order passed by the tax officer is erroneous and prejudicial to the interests of the revenue.

In (2022) 97ITR (Trib) SN 9 the commissioner invoked his power based on an audit objection alleging that the officer allowed deduction u/s 80P without any inquiry whether interest is earned on deposits made with state financial corporations or nationalised banks.

 section 263 however is silent on whether an audit objection is a good indicator to invoke revision powers as the CIT has to prima facie draw his satisfaction on the basis of his reexamination of assessment records of proceedings more than anything else.

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