Perhaps , in the history of income tax department , it must be the first time that more than 400 cases ( all pertaining to Asst. Yr 2008-09 ) were taken up  by commissioner of income tax suo-moto for action under section 263 of the Income Tax Act under which assessment /reassessment orders passed by the assessing officer were held as erroneous and prejudicial to the revenue. All these case have one common character tics. These are share capital formation companies .The affected companies have challenged those orders of CIT before Income Tax Appellate Tribunal . The first such large bunch of cases are pertaining to assessment year 2008-09 .