Revisional jurisdiction under section 263(1) upheld where identical issues were already decided in a connected reference.

The Patna High Court considered whether the Commissioner could invoke revisional jurisdiction under section 263(1) in relation to assessments made under section 143(1) under the Government scheme for new taxpayers in small-income groups, and whether the consolidated revision order was vitiated by natural justice concerns or mechanical exercise of power. Because the references involved the same controversy and identical facts as a connected matter already decided, the Court applied its earlier reasoning and treated the questions as covered. The referred questions were answered in favour of the Revenue, and the Commissioner's revisional action was upheld for all assessment years in reference.

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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 respect of assessments made under section 143(1) pursuant to the Government scheme for new taxpayers in small income groups, and whether the consolidated revisional order was invalid on the grounds of breach of natural justice, reliance on surmises and conjectures, and mechanical exercise of power.

Analysis: The references involved assessment years 1968-69 to 1973-74 and raised questions identical to those already considered in the connected matter involving the same legal controversy. The Court followed its earlier reasoning in the companion case and treated the issues as covered by that decision.

Conclusion: All the referred questions were answered in favour of the Revenue and against the assessee.

Final Conclusion: The Tribunal's view was not accepted, and the Commissioner's revisional action under section 263(1) was upheld for all the assessment years in reference.

Ratio Decidendi: Where the governing facts and questions are identical to an earlier decided reference, the same legal answer governs, and the referred questions may be answered consistently in favour of the same side.

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