Revision under income tax law remains available despite section 144B compliance where section 263 conditions are met.

An assessment completed in compliance with directions issued under section 144B of the Income-tax Act, 1961 is not immune from revision under section 263. The Court held that where the statutory conditions for revisional jurisdiction are otherwise satisfied, the Commissioner may revise such an assessment notwithstanding the fact that the Income-tax Officer acted on directions of the Inspecting Assistant Commissioner. The operative principle is that compliance with section 144B does not, by itself, oust the Commissioner's power under section 263.

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Issues: Whether the Commissioner of Income-tax could revise an assessment order under section 263 of the Income-tax Act, 1961, where the assessment had been completed in accordance with directions issued under section 144B of the Income-tax Act, 1961.

Analysis: The assessment had been framed after the Income-tax Officer made a reference under section 144B and acted on the directions issued by the Inspecting Assistant Commissioner. The question was whether compliance with those directions excluded the Commissioner's revisional power under section 263. The Court followed its contemporaneous view that an assessment made under section 144B is not immune from revision if the statutory conditions for section 263 are satisfied.

Conclusion: The Commissioner of Income-tax did have jurisdiction to revise the assessment under section 263 of the Income-tax Act, 1961. The question was answered in the negative and in favour of the Revenue.

Ratio Decidendi: An assessment completed in compliance with directions under section 144B of the Income-tax Act, 1961 is not, by that reason alone, beyond the revisional jurisdiction under section 263 of the Income-tax Act, 1961.

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