Final appellate orders cannot be undone through reassessment on the same issue under section 147.

A final appellate order allowing deductions binds the Assessing Officer, and reassessment under section 147 cannot be used to bypass that concluded determination on the same subject-matter. Where the appellate order has not been set aside in the manner known to law and has already been given effect to, the Revenue must pursue the appellate hierarchy rather than reopen completed assessments because a later Supreme Court decision suggests the earlier view was wrong. On that reasoning, reopening was held invalid and the reassessments were annulled.

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Issues: Whether the Assessing Officer could reopen the assessment under section 147 after the assessee's claim for deductions had been allowed by the appellate authority and that order had attained finality.

Analysis: The earlier appellate order allowing the deductions had not been set aside in the manner known to law and had already been given effect to by the Assessing Officer. A final appellate order binds the lower authorities, and the Assessing Officer cannot bypass that order by resorting to reassessment proceedings on the same issue merely because a later Supreme Court decision indicates that the earlier appellate view was erroneous. If the Revenue was aggrieved, its remedy lay in pursuing the appellate hierarchy, not in reopening concluded matters. The reassessment was therefore an impermissible attempt to undo a final appellate decision.

Conclusion: Reopening under section 147 was not valid in law, and the reassessments were rightly annulled.

Final Conclusion: The Revenue's appeals failed because the concluded appellate order could not be disturbed through reassessment on the same subject-matter.

Ratio Decidendi: A final appellate order on an assessment issue cannot be indirectly reviewed or neutralized by reassessment under section 147 unless it is first set aside in accordance with law.

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