JUDGMENT A.K. Goel, C.J. 1. This appeal has been preferred by the Revenue against order of learned Single Judge quashing notice issued under s. 263 of the IT Act, 1961 (the Act), followed by order dt. 28th March, 2000 on the ground that the error sought to be corrected by exercise of the suo motu revisional jurisdiction was not an error of jurisdiction and that the CIT had no jurisdiction to interfere with the order of assessment in the facts and circumstances of the present case. The assesses was assessed to income-tax in respect of the asst. yr. 1995-96 and in the course of the said assessment, assessee's claim in respect of deduction on account of payment of bonus was allowed under s. 43B of the Act even though the said claim had been allowed in the asst. yr. 1994-95 also. Though proceedings for rectification under s. 154/ 155 of the Act were initiated for rectifying the said error, the said proceedings were dropped. This led to initiation of suo motu revisional jurisdiction by issuing notice dt. 24th Jan., 2000 seeking to revise order of assessment dt. 11th March, 1998 on the ground that the same was erroneous and prejudicial to-the interest of Revenue in as much as the assesses had claimed the deduction twice. After due consideration of the reply of the assessee, the CIT passed order dt. 28th March, 2000 setting aside the order of assessment and directing the AO to re compute the assessment as per law after reasonable opportunity to the assessee. The error noticed by the CIT has been mentioned as follows : On perusal of the assessment records for the asst. yr. 1995-96 of the above-named assessee it is found by me that the assessment order for the asst. yr. 1995-96 was passed under s. 143(3) on 11th March, 1998 determining business loss at Rs. 6,10,758. It is also found that under the bonus account Rs. 79,71,328 (Rs. 37,00,000 being provision for 1994-95 and Rs. 42,71,328 being short provision of 1993-94) was debited to the P & L a/c and while computing total income for the asst. yr. 1995-96 only Rs. 37,00,000 being bonus provision was added back and Rs. 67,87,419 being bonus paid was deducted. Therefore, Rs. 42,71,328 being short provision of 1993-94 has been claimed as deduction in addition to the actual payment of bonus of Rs. 67,87,419. yr. 1995-96 only Rs. 37,00,000 being bonus provision was added back and Rs. 67,87,419 being bonus paid was deducted. Therefore, Rs. 42,71,328 being short provision of 1993-94 has been claimed as deduction in addition to the actual payment of bonus of Rs. 67,87,419. It is also revealed on perusal of the assessment records for the asst. yr. 1994-95 that while passing assessment order for the asst. yr. 1994-95 under s. 143(3) on 20th March, 1997 bonus of Rs. 42,74,392 was allowed on actual payment basis as per the certificate of auditor against provision of bonus of Rs. 25,00,000 for 1993-94. As the payment of bonus for the year 1993-94 amounting to Rs. 42,74,392 was allowed in the asst. yr. 1994-95 on actual payment basis, the amount of Rs. 42,71,328 being short provision bonus for 1993-94 claimed as deduction was required to be disallowed and added back to the income for the asst. yr. 1995-96 but the AO failed to do so. These actions of the AO have rendered the assessment order passed under s. 143(3) for the asst. yr. 1995-96 erroneous insofar as it is prejudicial to the interest of the Revenue. 2. It is clear from the above that the payment of bonus had been allowed as a deduction for the asst. yr. 1994-95 and the same could not be again claimed for the year 1995-96. The assessee could not show that on facts the error noticed by the CIT was not there. However, instead of filing an appeal against the order of the CIT, the assessee approached this Court under Art. 226 of the Constitution alleging that there was no justification for invoking jurisdiction under s. 263 of the Act as the said jurisdiction could be exercised only if there was a 'jurisdictional' error as held by a Division Bench of this Court in Rajendra Singh vs. State of Tripura (1990) 79 STC 10 (Gau) and other similar judgments. It was further submitted that the said power could not be exercised to interfere when power could be exercised for rectification under s. 154 or reassessment under s. 147 of the Act. It was further submitted that the said power could not be exercised to interfere when power could be exercised for rectification under s. 154 or reassessment under s. 147 of the Act. It was also submitted that the said power was not intended to be exercised to substitute the opinion of the CIT for the opinion of the AO and in any case mere suggestion of the audit party could not be the basis of exercise of the said power. Reliance was placed on State of Kerala vs. KM. Cheria Abdulla (1965) 16 STC 875 , Santlal Mehndi Ratta (HUF) vs. CIT (2002) 1 GLR 197, decision of this Court in Writ Petn. (Civil) No. 1416 of 2001, Bongaigaon Refinery & Petrochemicals Ltd. vs. Union of India & Ors. [reported at (2007) 211. CTR (Gau) 326-Ed.], Sirpur Paper Mills vs. CWT (1970) 77 ITR 6 (SC) and Jeewanlal (1929) Ltd. vs. Addl. CIT & Ors. (1977) 108 ITR 407 (Col). 3. The writ petition was opposed and it was submitted that merely because rectification proceedings were dropped, did not affect jurisdiction of the CIT under s. 263 when such jurisdiction was exercised upon a finding that order of the AO was erroneous and prejudicial to the interest of the Revenue. Mere fact that there was an audit report also taking the same view did not affect the jurisdiction of the CIT. Objection was also taken that the order of the CIT was appealable under s. 253(1)(c) and therefore in view of the said alternative remedy, the writ petition ought not to be entertained. 4. Learned Single Judge held that the writ petition could be entertained as order of the CIT was without jurisdiction. If the AO allowed the deduction on account of bonus, the CIT could not substitute his opinion for that of the AO. The CIT could also not exercise revisional jurisdiction when the matter was covered by the scope of rectification jurisdiction. The relevant findings recorded by the learned Single Judge are: 24. In the present case, it is after examination of the books of account under s. 43B of the Act that the assessing authority has allowed the deduction on account of bonus in exercise of its powers under s. 143(3). The relevant findings recorded by the learned Single Judge are: 24. In the present case, it is after examination of the books of account under s. 43B of the Act that the assessing authority has allowed the deduction on account of bonus in exercise of its powers under s. 143(3). The AO, having acted within his jurisdiction, in allowing the claim of bonus as deduction, it was not open to the CIT to consider the said order as erroneous merely because, in his view, certain amount of bonus, allowed as deduction, should have been disallowed, particularly, when the impugned order of the CIT does not show how the order of assessment can be said to be order passed without jurisdiction or an order passed beyond jurisdiction or wholly contrary to jurisdiction. 30. From what have been discussed above, it becomes abundantly clear that a revisional authority cannot entrench upon the powers, which are expressly reserved by the Act in favour of the other authorities. The Act, nowhere, authorizes the revisional authority to intrude into the inquiries properly made by the assessing authority and to reopen an already completed assessment. 32. From the facts as discussed above, it is clear that in the case at hand, the CIT has initiated the suo motu revisional proceeding, under s. 263, entirely based on the objection raised by the internal audit authority. There is nothing either in the impugned notice dt. 24th Jan., 2000, or in the impugned order dt. 28th March, 2000, to show that the CIT has applied his independent mind and has come to the conclusion that the assessment made needs to be revised. Moreover, the suo motu revisional jurisdiction cannot be invoked, under s. 263, for the purpose of making roving enquiry by directing an authority, as has been done in the present case, to, again verify an issue, which was verified by the AO and thereby settled and concluded by him. Such an approach is not permitted within the parameters of the powers conferred on a revisional authority under s. 263, for, allowing exercise of such powers would amount to permitting the revisional authority to reopen an assessment, which has been made in exercise of jurisdiction vested in the assessing authority, but while making the assessment, a mistake has been committed by the assessing authority unless it is alleged that the deductions allowed were wholly impermissible in law. Furthermore, though a revisional proceeding has been initiated against the order of assessment made on 11th March, 1998, no revisional proceeding was initiated against the order dt. 7th Jan., 2000, whereby the assessing authority had dropped the rectification proceeding initiated under s. 154. Thus, while the order passed on 7th Jan., 2000 remains unchallenged and unaltered, the order dt. 11th March, 1998, gets reopened. When a rectification proceeding is initiated under s. 154 and a final order dropping the rectification proceeding is passed, the effect is that the assessment order has merged into the order made in the rectification proceeding. In the case at hand, the assessment order dt. 11th March, 1998, had merged into the order dt. 7th Jan., 2000. In such circumstances, without interfering with the order dt. 7th Jan., 2000, the order dt. 11th March, 1998, could not have been reached by the revisional authority and set aside. Viewed thus, it is clear that the impugned notice dt. 24th Jan., 2000, and the order dt. 28th March, 2000, passed by the CIT under s. 263 are absolutely without jurisdiction and not tenable in law. 34. From what have been pointed out above, it is clear that the CIT initiated the revisional proceeding influenced by the objection raised by the internal audit party and has not applied his independent mind while passing the impugned order. Hence, the impugned order is liable to be set aside and quashed. 38. What crystallizes from the above discussion is that in the present case, when there was no lack of jurisdiction on the part of the assessing authority, in passing the order of assessment and the assessing authority had not exceeded its jurisdiction in passing the order of assessment, the order cannot be termed erroneous, within the meaning of s. 263, to enable the CIT to invoke powers under s. 263 of the Act. 5. We have heard Mr. Sanjay Sarma, learned standing counsel for the Revenue. None appears for the assessee though the service is complete as noticed in order dt. 25th Nov., 2010. 6. 5. We have heard Mr. Sanjay Sarma, learned standing counsel for the Revenue. None appears for the assessee though the service is complete as noticed in order dt. 25th Nov., 2010. 6. Learned counsel for the Revenue challenged the view taken by learned Single Judge by submitting that there was clear and patent error in the order of the AO in not taking into account the fact that the assessee had already availed of the same deduction in the earlier assessment year which was not disputed by the assessee. In these circumstances, the order of the AO could certainly be held to be erroneous. The expression 'erroneous' did not include mere error of jurisdiction but also covered a case of wrong assumption of facts or incorrect application of law or absence of application of mind. He submits that law laid down in Rajendra Singh (supra) has been explained in a recent Full Bench judgment of this Court dt. 8th Feb., 2012 in IT Appeal No. 2 of 2008, CIT vs. Jawahar Bhattacharjee [reported at (2012) 247 CTR (Gau)(FB) 473: (2012) 67 DTR (Gau)(FB) 217-Ed.]. He also submitted that mere fact that the error could be rectified or resort could be taken to reassessment would be no bar to exercise of revisional jurisdiction if the case falls within the purview of the said jurisdiction. Mere fact that the audit party had also raised some objection did not affect the jurisdiction of the revisional authority. It was not a case where the revisional authority had substituted its opinion for that of the AO but a case where the AO failed to notice the factual aspect and made assessment on wrong assumption of facts and without application of mind. 7. We have given due consideration to the submission made on behalf of the Revenue. We are of the view that the learned Single Judge was not justified in interfering with the order of the CIT passed under s. 263 of the Act. Even if we ignore the objection of alternative remedy of appeal, available to the assessee under s. 253(1)(c) of the Act, the fact remains that an error was noticed by the CIT in the order of the AO that the assessee had made claim for the same deduction twice and after noticing the said error, the same was corrected. Even if we ignore the objection of alternative remedy of appeal, available to the assessee under s. 253(1)(c) of the Act, the fact remains that an error was noticed by the CIT in the order of the AO that the assessee had made claim for the same deduction twice and after noticing the said error, the same was corrected. In these circumstances, it could not be held that such an order was beyond the revisional jurisdiction of the CIT. Similar objection of the audit party did not in any manner affect the revisional jurisdiction, nor the fact that the error could be rectified by the AO or the AO could have taken resort to reassessment provision could be a bar to exercise of revisional jurisdiction. It was also not a case of substitution of opinion of revisional authority for the opinion of the AO. Thus, learned Single Judge was not justified in interfering with the revisional order of the CIT under s. 263 of the Act. In view of above, we allow this appeal, set aside the impugned order passed by the learned Single Judge and dismiss the writ petition filed by the respondent assessee.