Remand proceedings are confined to binding appellate findings; settled issues cannot be reopened, while fresh matters may still be examined.

In remand proceedings, the Assessing Authority remains bound by issues conclusively decided by the Tribunal and cannot reopen matters that have attained finality, including the assessee's entitlement to concessional treatment and the admissibility of additional forms filed in appeal. Those settled findings could not be re-agitated. However, the remand did not extinguish jurisdiction altogether: the Assessing Authority could still examine fresh or untouched matters, provided it acted within the Tribunal's directions and consistent with law. The notices were therefore not quashed in full, but reopening of decided issues was restrained.

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Issues: Whether, after a limited remand by the Tribunal, the Assessing Authority could reopen issues already decided by the Tribunal and attained finality, while also examining fresh matters not covered by the remand.

Analysis: The Tribunal had conclusively decided the assessee's entitlement to concessional treatment on Forms-D, the admissibility of additional Forms-C, D and F filed in appeal, and had disapproved the rejection of books of accounts for the relevant years. Those findings bound the Assessing Authority in the remand proceedings and could not be re-agitated. At the same time, the power of the Assessing Authority in remand was not completely curtailed: subject to the Tribunal's directions and binding findings, fresh or untouched issues could still be examined in accordance with law.

Conclusion: The notices were not quashed in full, but the Assessing Authority was restrained from reopening issues already decided by the Tribunal and attaining finality.

Final Conclusion: The remand proceedings may continue only within the bounds of the Tribunal's final findings, and the Assessing Authority cannot travel beyond those findings to reconsider settled matters.

Ratio Decidendi: In remand proceedings, the lower authority remains bound by issues conclusively decided by the appellate authority, but may examine only such fresh matters as are not covered by the binding remand directions or final findings.

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