Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee
4. The intricate legal issue relating to lack of jurisdiction vested in Pr.Commissioner of Income Tax under section 263 was not there in the knowledge of the petitioner appellant as well as his regular counsel Mr. Mahesh Chander Khungar, resulting need for filing of appeal against impugned order dated 29.03.2016 never cropped up in their mind, inter-alia no appeal