Merger doctrine limits revisional power: Commissioner cannot annul a merged assessment order or issue detailed best judgment directions.

The appellate order displaced the original assessment order, so the assessment had no independent existence after appeal and had merged into the appellate decision. In suo motu revision, the Commissioner could examine and correct only any error in the appellate order, but could not directly annul the merged assessment order. The revisional power also did not authorise detailed directions on how a best judgment assessment ought to have been framed, because that would exceed correction of the appellate authority's error. The Commissioner's order was therefore set aside to the extent it cancelled both orders, and the matter was remitted for fresh decision within the proper revisional limits.

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Issues: Whether, in exercise of suo motu revisional power, the Commissioner could set aside both the assessment order and the appellate order, and whether the assessment order had merged in the appellate order.

Analysis: The appellate authority's decision displaced the original assessment order, so the latter had no independent existence after the appeal was decided. In revision, the Commissioner could correct only the error, if any, in the appellate order and could not directly annul the assessment order that had merged with it. The revisional power also did not extend to detailed directions on how best judgment assessment ought to have been made, as that would go beyond correction of the appellate authority's error.

Conclusion: The Commissioner's order was set aside to the extent it cancelled the assessment order along with the appellate order, and the matter was remitted for fresh decision within the proper revisional limits.

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