Revision power under section 263: Commissioner may revise ITO order portions not covered and severable from the appellate order. Commissioners may exercise revision under section 263 only over points in the Income tax Officer's order that were not covered, expressly or impliedly, by the Appellate Assistant Commissioner's order and which are severable from the parts affirmed by the appellate order; if the appellate order wholly affirms the ITO's order, the ITO's order is merged and not subject to revision.
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Provisions expressly mentioned in the judgment/order text.
Revision power under section 263: Commissioner may revise ITO order portions not covered and severable from the appellate order.
Commissioners may exercise revision under section 263 only over points in the Income tax Officer's order that were not covered, expressly or impliedly, by the Appellate Assistant Commissioner's order and which are severable from the parts affirmed by the appellate order; if the appellate order wholly affirms the ITO's order, the ITO's order is merged and not subject to revision.
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