Revisional jurisdiction over erroneous tax orders extends beyond assessment orders and covers proceedings dropped under section 23A.

The Commissioner's revisional power under section 33B(1) of the Indian Income-tax Act, 1922 extends to any order of the Income-tax Officer that is erroneous and prejudicial to the revenue, and is not confined to assessment orders. An approval by the Appellate Income-tax Commissioner of the recommendation to drop proceedings under section 23A(1) did not itself amount to an order under section 23A(8). Because the Income-tax Officer's order was passed in proceedings under the Act, the Commissioner could set it aside and direct a fresh order under section 23A(1).

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Issues: Whether the Commissioner had jurisdiction under section 33B(1) of the Indian Income-tax Act, 1922 to revise the Income-tax Officer's order dropping proceedings under section 23A(1), notwithstanding the Appellate Income-tax Commissioner's approval.

Analysis: The Commissioner's power under section 33B(1) extends to any order passed by the Income-tax Officer that is erroneous and prejudicial to the interests of the revenue, and is not confined to assessment orders alone. The approval given by the Appellate Income-tax Commissioner to drop the proceedings was only an approval of the recommendation and did not amount to an order under section 23A(8). Since the Officer's order was an order passed in proceedings under the Act, the Commissioner could set it aside and direct a fresh order under section 23A(1).

Conclusion: The Commissioner had jurisdiction under section 33B(1) to pass the revisional order, and the question was answered in the negative, in favour of the revenue.

Ratio Decidendi: The Commissioner's revisional jurisdiction under section 33B(1) of the Indian Income-tax Act, 1922 extends to any erroneous order prejudicial to revenue passed by the Income-tax Officer, and is not limited to assessment orders.

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