Revisional bar under Section 264(4)(c) applies once the assessment order is appealed to the Tribunal, even if the specific relief was not raised.

Section 264(4)(c) bars revisional jurisdiction where the assessment order itself has already been made the subject of an appeal to the Appellate Tribunal; the bar does not depend on whether the particular relief later sought in revision was specifically urged in that appeal. The assessment order is treated as a single unit for appeal and revision purposes, and the limited scope of the Tribunal's consideration does not narrow the meaning of "order" in the revisional prohibition. Applying the same reasoning as under the identical earlier provision in the 1922 Act, the Commissioner was justified in refusing revision.

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Issues: Whether the Commissioner was barred by Section 264(4)(c) of the Income-tax Act, 1961 from entertaining a revision petition when the assessment order had already been made the subject of an appeal to the Appellate Tribunal, even though the particular relief sought in revision had not been raised in the appeal.

Analysis: The bar in Section 264(4)(c) turns on whether the order sought to be revised has been made the subject of an appeal to the Appellate Tribunal, not on whether every item of relief now claimed was specifically urged in that appeal. The statutory scheme treats the assessment order as a single unit for the purposes of appeal and revision, and the scope of the Tribunal's consideration does not control the ambit of the word "order" in the revisional bar. The reasoning under Section 33A(2) of the Indian Income-tax Act, 1922, which contains an identical prohibition, supports the same interpretation under the 1961 Act.

Conclusion: The Commissioner was justified in refusing revision and the petitioner's challenge failed.

Ratio Decidendi: Where an assessment order has been made the subject of an appeal to the Appellate Tribunal, the Commissioner cannot invoke revisional jurisdiction under Section 264(4)(c) of the Income-tax Act, 1961 over that order, even if the specific relief later sought in revision was not part of the appeal.

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