Appealability of Revisional Assessments: revisional assessments under appellate directions remain appealable and appeals must be admitted.

An order directing the Income-tax Officer to revise or amend an assessment pursuant to appellate directions brings that revisional act within the statutory concept of assessment under section 23, so that a substantive right of appeal under section 30(1) exists against the revisional assessment; procedural limitations such as limitation under section 30(2) apply by reference to the notice of demand from the revised assessment but do not oust the right of appeal. Reliance on decisions concerning miscellaneous applications outside the Act was held distinguishable; the Tribunal ought to have admitted the appeals.

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Issues: Whether the Appellate Tribunal was justified in refusing to admit the assessee's appeals against the Income-tax Officer's revisions of assessments (for assessment years 1944-45, 1945-46 and 1946-47) made pursuant to the Tribunal's earlier directions.

Analysis: The statutory scheme grants a substantive right of appeal under section 30(1) against orders of assessment made under section 23. An order by the Appellate Tribunal under section 33(4) directing the Income-tax Officer to revise or amend an assessment brings the revisional act of the Income-tax Officer within the scope of section 23; the revisional assessment thus partakes the character of an assessment from which an appeal lies. Authorities including Privy Council and subsequent Supreme Court and High Court decisions recognise that an assessment is final only when all appellate proceedings conclude; until then revision pursuant to appellate directions remains within the assessment process. Procedural prerequisites such as limitation under section 30(2) apply by reference to the notice of demand arising from the revised assessment; they do not oust the substantive right of appeal. Distinctions with cases founded on miscellaneous applications not recognised by the Act (where no appeal under section 33(1) existed) are material and render Arunachalam Chettiar distinguishable on the facts. The Tribunal's reliance on Arunachalam Chettiar was a misapplication where there was a regular appeal to the Appellate Assistant Commissioner and a direction under section 33(4).

Conclusion: The Tribunal was not justified in refusing to admit the appeals; the appeals against the revisional assessments should have been admitted - decision in favour of the assessee.

Ratio Decidendi: A revision or amendment of an assessment by the Income-tax Officer made pursuant to an order of the Appellate Tribunal under section 33(4) is an assessment within section 23 and is appealable under section 30(1), preserving the assessee's substantive right of appeal.

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