Limited remand confines reassessment to remitted issues; a concluded claim cannot be reopened by a later Supreme Court ruling.

A reassessment made after a limited remand is confined to the matters actually remitted for reconsideration, and the assessing authority cannot reopen issues that were not appealed against or were left undisturbed. The appellate order here was treated as a partial remand only on speculative losses, while the loom-hour receipt issue had attained finality. A later Supreme Court ruling did not expand the scope of the remand or permit a fresh plea on that concluded issue. The assessee's new claim was therefore not entertainable in the reassessment proceedings, and the question was answered in favour of the revenue.

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Issues: Whether, after an assessment is set aside only on a limited point and remanded for fresh consideration, the assessee can raise a new plea in the reassessment proceedings based on a subsequent Supreme Court decision.

Analysis: The order of the Appellate Assistant Commissioner was construed as a partial remand confined to the specific issue of speculative losses. The earlier assessment on the receipt from sale of loom hours had not been appealed against on that point, and that issue had not been disturbed by the appellate order. In reassessment proceedings following a limited remand, the Income-tax Officer is bound by the scope of the remand and cannot travel beyond the matters remitted for reconsideration. The later Supreme Court ruling on loom-hour receipts did not enlarge the remand or reopen the concluded issue.

Conclusion: The assessee could not raise the new plea in the reassessment proceedings, and the question was answered in favour of the revenue.

Final Conclusion: A reassessment following a restricted remand is confined to the remitted matters alone, and issues not carried in appeal or not set aside remain concluded.

Ratio Decidendi: Where an appellate authority sets aside only a specific part of an assessment and remands the matter for limited reconsideration, the reassessing authority has jurisdiction only within the remand directions and cannot entertain a fresh claim on a concluded issue.

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