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The instructions/guidelines could not have overriding effect on the statutory provisions of law. The main function under Section 66A is supervisory, in order to ensure that on account of any error, there is no loss of revenue, caused to the Department. To ensure so he can enhance, modify, cancel or direct for fresh assessment to be made. It is also important to consider that both of these ingredient i.e. (i) if the order passed by the Assessing Officer is erroneous; (ii) if the same is prejudicial to the interest of the revenue;, should arise out of the assessment of the Assessing Officer simultaneously so that IAC could invoke the revisional jurisdiction under Section 66A. If any one of the above mentioned ingredient is not available, then the IAC could not invoke the jurisdiction un...
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