Revision jurisdiction under income tax law extends to orders passed under superior authority directions, not just standalone assessments.

Section 263 of the Income-tax Act was held to cover an order passed by an Income-tax Officer with the approval or directions of a superior authority under section 144B. The argument that such an order was outside the phrase "order passed by the Income-tax Officer" was rejected. The Court relied on the consistent view of several High Courts and the later amendments to the Act, and found no basis to confine section 263 so as to exclude orders made in pursuance of directions under sections 144A or 144B. The Commissioner therefore had jurisdiction to revise the order, and the issue was decided against the assessee.

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Issues: Whether the Commissioner of Income-tax had jurisdiction under section 263 of the Income-tax Act, 1961 to revise an order passed by the Income-tax Officer with the approval or directions of a superior authority under section 144B.

Analysis: The exclusion urged by the assessee, namely that the expression "order passed by the Income-tax Officer" in section 263 did not extend to orders passed in pursuance of directions under section 144B, was rejected. The interpretation adopted by the High Court was consistent with the uniform view taken by several High Courts on the same question. In light of the subsequent amendments to the Act, there was no basis to confine the scope of section 263 so as to exclude orders passed by the Income-tax Officer on the directions of a superior authority under section 144A or 144B.

Conclusion: The Commissioner of Income-tax had jurisdiction under section 263 to revise such an order, and the answer was against the assessee.

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