Limited remand confines reassessment to remitted issues and bars reopening final appellate findings left unchallenged.

On a limited remand, the assessing authority is confined to the precise subject-matter remitted by the appellate order and must act consistently with findings that have already attained finality. Where the first appellate authority had expressly upheld rejection of the books of account and remitted only verification of the C forms, that adverse finding could not be reopened in later proceedings because it was not challenged and remained conclusive between the parties. The assessing authority therefore lacked jurisdiction to re-adjudicate the settled issue, and the higher court upheld the view that the concluded appellate finding could not be reagitated after partial remand.

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Issues: Whether, after a partial remand by the first appellate authority, the assessing authority could reopen and re-adjudicate an issue that had already been conclusively decided and had not been challenged.

Analysis: The remand order did not set aside the entire assessment. The first appellate authority had specifically upheld the rejection of the books of account and remitted the matter only for verification of the two C forms. Since the assessee did not challenge the adverse finding on rejection of books, that finding attained finality between the parties. After a limited remand, the assessing authority may proceed on fresh material only within the scope of the remand and must act consistently with the appellate order. It cannot reopen a matter already concluded in appeal and left undisturbed.

Conclusion: The assessing authority had no jurisdiction to reopen the issue of rejection of books of account, and the challenge to the Tribunal's view failed.

Final Conclusion: The revision was dismissed because the concluded appellate finding could not be reagitated in proceedings after a limited remand.

Ratio Decidendi: On a limited remand, the assessing authority is confined to the subject-matter remanded and cannot reopen issues already finally determined in appeal and not challenged further.

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