https://www.taxtmi.com/caselaws?id=25721 The appellate jurisdiction of the Appellate Assistant Commissioner extends to matters arising from assessment proceedings, including interest charged or omitted under sections 139(8) and 217. Those matters form part of the assessment process and are not treated as separate for merger purposes. Accordingly, the appellate order displaces the original assessment order to the extent of the appellate authority's competence, and the Commissioner cannot revise that merged portion under section 263. The Explanation to section 251 supports consideration of any matter arising from the proceedings, and later decisions on different statutory settings do not alter this merger principle. en-us Tue, 21 Apr 1987 00:00:00 +0530 Sat, 30 Jan 2010 13:59:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=25721 The appellate jurisdiction of the Appellate Assistant Commissioner extends to matters arising from assessment proceedings, including interest charged or omitted under sections 139(8) and 217. Those matters form part of the assessment process and are not treated as separate for merger purposes. Accordingly, the appellate order displaces the original assessment order to the extent of the appellate authority's competence, and the Commissioner cannot revise that merged portion under section 263. The Explanation to section 251 supports consideration of any matter arising from the proceedings, and later decisions on different statutory settings do not alter this merger principle. Case-Laws Income Tax Tue, 21 Apr 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=25721