https://www.taxtmi.com/caselaws?id=15616 Revision under section 263 of the Income-tax Act is not barred by merger where the appellate proceeding and the revisional proceeding concern different subject matters. The High Court also treated the objection based on merger as a pure question of law, so the Tribunal was competent to permit it to be raised as a new ground. On the merits, the Tribunal's view that the Commissioner lacked jurisdiction solely because of merger was held inconsistent with the governing law, and the revisionary bar was rejected. The matter was remitted for examination of the assessee's case on merits. en-us Wed, 16 Sep 1998 00:00:00 +0530 Wed, 26 Aug 2009 13:30:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=15616 Revision under section 263 of the Income-tax Act is not barred by merger where the appellate proceeding and the revisional proceeding concern different subject matters. The High Court also treated the objection based on merger as a pure question of law, so the Tribunal was competent to permit it to be raised as a new ground. On the merits, the Tribunal's view that the Commissioner lacked jurisdiction solely because of merger was held inconsistent with the governing law, and the revisionary bar was rejected. The matter was remitted for examination of the assessee's case on merits. Case-Laws Income Tax Wed, 16 Sep 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=15616