Scope of remand controls reassessment: an assessing authority cannot exceed the appellate directions after remand.

An assessing authority acting after remand must confine itself to the scope of the appellate directions and cannot enlarge the remand or travel beyond its terms. If the appellate order leaves an issue open, the authority may proceed according to law; if the remand is limited, further assessment action must remain within those limits. The discussion also notes that powers to direct further enquiry and to support the appellate order do not authorise action outside the remand. The operative principle is that post-remand proceedings are binding on the remand terms.

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Issues: Whether, after remand by the appellate authority, the Income-tax Officer could take steps only within the scope of the remand order and not enlarge the remand while making the assessment.

Analysis: The challenge to the proceeding under section 144B was treated as no longer surviving. The controlling question was the effect of the remand order. Where the appellate order leaves the matter open, the authority below may proceed in accordance with law. Where, however, the remand is limited, the authority on remand cannot travel beyond the directions contained in the appellate order or enlarge the scope of the remand. The Tribunal's powers to direct further enquiry and the respondent's entitlement to support the appellate order were noted, but they did not authorise action beyond the remand.

Conclusion: The authorities were entitled to proceed after remand, but only within the limits of the remand order and not beyond it.

Ratio Decidendi: An assessing authority acting after remand is bound by the terms of the remand and cannot exceed or expand the scope of the appellate directions.

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