https://www.taxtmi.com/caselaws?id=19882 The court held that the revision application was not barred by section 264(4)(c) as the specific claim was not raised or decided by lower authorities. It emphasized the broad scope of the Commissioner's revisional jurisdiction, allowing relief for claims not initially made. Regarding the doctrine of merger, only decisions expressly or impliedly decided by the Appellate Assistant Commissioner merge into the appellate order. The court quashed the Commissioner's order and directed reconsideration of the application, clarifying the application of the bar under section 264(4)(c) and the Commissioner's authority to grant relief for unclaimed issues. en-us Tue, 14 Sep 1993 00:00:00 +0530 Tue, 10 Nov 2009 13:28:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=19882 The court held that the revision application was not barred by section 264(4)(c) as the specific claim was not raised or decided by lower authorities. It emphasized the broad scope of the Commissioner's revisional jurisdiction, allowing relief for claims not initially made. Regarding the doctrine of merger, only decisions expressly or impliedly decided by the Appellate Assistant Commissioner merge into the appellate order. The court quashed the Commissioner's order and directed reconsideration of the application, clarifying the application of the bar under section 264(4)(c) and the Commissioner's authority to grant relief for unclaimed issues. Case-Laws Income Tax Tue, 14 Sep 1993 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=19882