Section 260A appeal fails where the underlying section 263 revision is invalid and no substantial question of law survives.

Revenue's section 260A appeal failed because the assessment was merely consequential to the section 263 revisional order, and once that revisional order had been held invalid, no independent error in the Tribunal's decision remained. The court found that no substantial question of law arose for consideration and, on that basis, the appeal was not maintainable on merits and was decided against the Revenue.

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Issues: Whether the Revenue's appeal under section 260A of the Income-tax Act, 1961 could survive when the revisional order under section 263 of the Income-tax Act, 1961 had already been held invalid.

Analysis: The assessment made pursuant to the section 263 order was consequential in nature. Since the revisional order had been set aside, no independent error in the Tribunal's order was shown. No substantial question of law arose for consideration.

Conclusion: The appeal was not maintainable on merits and was decided against the Revenue.

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