- (1.) In this appeal by the assessee against the order under section 263 of the Income Tax Act (hereinafter referred to as the Act), passed by the Commissioner, Central Circle, Kanpur on 22-3-1999, the assessee has assailed the Commissioners order by way of as much as 13 grounds extracted as under : The Commissioner (Central), Kanpur, has erred against law and facts on record in framing the order dated 22-3-1999, under section 263 of the Income Tax Act contrary of law and facts on record.
(2.) The Commissioner (Central) is in error in passing an order under section 263 with respect to order of assessment dated 27-3-1997, despite the facts that the order of assessment dated 27-3-1997, was neither erroneous nor prejudicial to the interests of the revenue on the facts and circumstances of the case.
(3.) The Commissioner while framing the order under section 263 had failed to take cognizance of the record available at the time of its examination by the learned Commissioner in accordance with the section 263, Explanation clause (b), of the Income Tax Act, 1961.;