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Whether on the facts and in the circumstances of thecasethe CIT has jurisdiction to revise an assessment made by the AO allowing the deduction from computation of taxation of profits of the Industrial Undertaking u/s 80-I of the Act in respect of the amounts of duty draw back received for the manufactured goods exported by it?

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Sec. 263 of Income Tax Act, 1961— Revision — There is no quibble that the Commissioner (Appeals) as per the explanation to Section 251 can consider the matter arising out of the proceedings in which the appeal is filed irrespective of the fact that the said matter has not been raised by the assessee and there is also no dispute/ that as per explanation 1(c) to Section 263(1), the revision cannot be done of the issue which has been considered and decided in appeal - NAHAR SPINNING MILLS LTD. V/s CIT - [2020] 427 ITR 131 (P&H)