Revisional jurisdiction over section 143(1) assessments under the small taxpayer scheme upheld against immunity claims.

An assessment made under section 143(1) pursuant to the Government scheme for small taxpayers was treated as amenable to revision under section 263(1), and the court followed its earlier rulings on identical facts to reject the contention that such an order was immune from revisional scrutiny. Applying those precedents, the court held that the Tribunal was not justified in cancelling the Commissioner's revision order for the relevant assessment years. The questions were answered in the negative, in favour of the Revenue and against the assessee.

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Issues: Whether the Commissioner of Income-tax could exercise revisional jurisdiction under section 263(1) of the Income-tax Act, 1961 in relation to an assessment made under section 143(1) pursuant to the Government scheme for small taxpayers, and whether the Tribunal was justified in cancelling the Commissioner's revision order for the relevant assessment years.

Analysis: The questions were governed by earlier decisions of the same court on identical facts, in which it had been held that an order made under section 143(1) under the said scheme was not immune from revision under section 263(1). The court followed those precedents and treated the controversy as covered by its prior rulings.

Conclusion: The questions were answered in the negative, i.e. in favour of the Revenue and against the assessee.

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