v. Shreeji Prints (P.) Ltd.,\n5. The Tribunal has found that in the order passed by the PCIT, Explanation 2 of\nSection 263 of the Act, 1961 is made applicable. The Tribunal observed that the\nPCIT has not mentioned in the show cause notice to invoke the Explanation 2 of\nsection 263 of the Act 1961. Therefore, by invocation