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Principal Commissioner cannot revise order of Appellate Tribunal as it is contrary to principles of merger, judicial discipline, and res-judicata. The issue before authorities was confined to entitlement of deduction u/s 80IC, whether 100% or 30%. Tribunal settled matter in favor of assessee. Principal Commissioner concluded assessee not entitled to 100% deduction, amounting to revision of Tribunal's order, which is beyond jurisdiction. An authority cannot revise order merged with higher authority's order, as it would lead to chaos and unending litigation. Every litigation must be put to rest at some stage.
Principal Commissioner cannot revise order of Appellate Tribunal as it is contrary to principles of merger, judicial discipline, and res-judicata. The issue before authorities was confined to entitlement of deduction u/s 80IC, whether 100% or 30%. Tribunal settled matter in favor of assessee. Principal Commissioner concluded assessee not entitled to 100% deduction, amounting to revision of Tribunal's order, which is beyond jurisdiction. An authority cannot revise order merged with higher authority's order, as it would lead to chaos and unending litigation. Every litigation must be put to rest at some stage.
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