ORDER–Point not subject-matter of appeal.
The issue regarding the allowance of certain deduction was not the subject matter of appeal hence was open for revision by the Commissioner under section 263.
The order of the Income Tax Officer in respect of the aforesaid deduction allowed by the Income Tax Officer was not the subject-matter of appeal before the Appellate Assistant Commissioner and did not merge into the order of the Appellate Assistant Commissioner. The Commissioner had the jurisdiction to pass on order under section 263.
Also to current assessment years.
Income Tax Act 1961 s.263