When 133 cr is involved, second thoughts are inevitable. But the I-T Appellate Tribunal's (ITAT) Delhi bench has reminded the tax administration that Sec 263 of I-T Act is not a statutory licence for second thoughts, especially when they arise after a completed scrutiny assessment. Last month, in an order involving senior advocate Mukul Rohatgi's AY 2020-21 return, ITAT quashed the revisionary order under Sec 263 and restored the completed scrutiny assessment passed under Sec 143(3) read with Sec 144B. So, has ITAT reshaped Sec 263 law? No. It has firmly redrawn its boundaries at a time when those boundaries have been under pressure. For AY 2020-21, Rohatgi's return was scrutinised and assessed at about 2133 cr. Subsequently, the principal commissioner invoked Sec 263 on three grounds: Characterisation of certain MF gains (long-term vs short-term).