1998 (4) TMI 162 - ITAT DELHI-C

Extract:
.......e assumed on the basis of change of opinion. We, therefore, hold that conditions precedent for assuming jurisdiction under section 263 of the Act did not exist in the facts and circumstances of the present case. Accordingly, we quash the orders passed under section 263 of the Act. 80. In the result, appeals of the assessee, stand allowed, protanto.