Revisionary order set aside, so consequential assessment and appellate orders lost legal effect and were quashed.

When a revisionary order under Section 263 is set aside, any assessment order made solely in pursuance of that revision and the consequential appellate order lose independent legal existence and are treated as non est. The downstream orders cannot survive once the foundational revisionary order disappears, because their validity depends entirely on that basis. The Tribunal accordingly held that the consequential assessment and appellate orders were unsustainable and set them aside in favour of the assessee.

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Issues: Whether the assessment order passed under Section 143(3) of the Income-tax Act, 1961, and the consequential appellate order survived after the revisionary order under Section 263 of the Income-tax Act, 1961 had already been set aside.

Analysis: The order under Section 263 had been annulled by the Tribunal in earlier proceedings. Once that foundation disappeared, the assessment order made in pursuance of the revisionary order and the appellate order arising therefrom had no independent legal existence and were treated as non est.

Conclusion: The consequential orders were set aside and the appeal was allowed in favour of the assessee.

Final Conclusion: The disappearance of the revisionary foundation rendered the downstream assessment and appellate orders unsustainable.

Ratio Decidendi: When the foundational revisionary order is set aside, all consequential proceedings and orders based solely on it cease to have legal effect.

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