https://www.taxtmi.com/caselaws?id=168412 Section 33B of the Income-tax Act, 1922 conferred revisional power on the Commissioner only subject to the express statutory limits in that provision: the assessment order had to be erroneous and prejudicial to the revenue, it could not be an order of reassessment under section 34, and action had to be taken within two years. Because the section contained no express bar based on pendency of an appeal, the Commissioner could still revise an assessment order even while an appeal was pending before the appellate authority. The view that such pendency implied a further restriction was rejected as adding a limitation not found in the statute. en-us Tue, 11 Aug 1959 00:00:00 +0530 Thu, 26 Feb 2015 18:28:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=168412 Section 33B of the Income-tax Act, 1922 conferred revisional power on the Commissioner only subject to the express statutory limits in that provision: the assessment order had to be erroneous and prejudicial to the revenue, it could not be an order of reassessment under section 34, and action had to be taken within two years. Because the section contained no express bar based on pendency of an appeal, the Commissioner could still revise an assessment order even while an appeal was pending before the appellate authority. The view that such pendency implied a further restriction was rejected as adding a limitation not found in the statute. Case-Laws Income Tax Tue, 11 Aug 1959 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=168412