https://www.taxtmi.com/caselaws?id=5650 The retrospective Explanation to section 263 of the Income-tax Act enlarges revisional power where an assessment order has been appealed only in part. Matters in the assessment that were not considered or decided by the appellate authority do not merge with the Commissioner (Appeals) order, so revision can still be exercised over those items. On that basis, the three disputed items, not raised in the assessee's appeal, remained open to revision under section 263, and the issue was decided in favour of the Revenue. en-us Tue, 23 Jan 1996 00:00:00 +0530 Wed, 15 Oct 2025 13:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5650 The retrospective Explanation to section 263 of the Income-tax Act enlarges revisional power where an assessment order has been appealed only in part. Matters in the assessment that were not considered or decided by the appellate authority do not merge with the Commissioner (Appeals) order, so revision can still be exercised over those items. On that basis, the three disputed items, not raised in the assessee's appeal, remained open to revision under section 263, and the issue was decided in favour of the Revenue. Case-Laws Income Tax Tue, 23 Jan 1996 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5650