https://www.taxtmi.com/caselaws?id=27025 The Full Bench concluded that the Commissioner of Income-tax lacks jurisdiction to entertain a revision petition under section 264 of the Income-tax Act, 1961, when the order of the Appellate Assistant Commissioner is already under appeal before the Tribunal. The doctrine of merger was examined, emphasizing that the entire order merges into the appellate order, preventing the Commissioner's revisional jurisdiction. Additionally, the express bar under section 264(4) prohibits revision of orders subject to Tribunal appeals, irrespective of the relief sought or appealing party. The judgment stressed legal consistency and upheld the principle of merger, restricting the Commissioner's revision powers. en-us Fri, 26 Oct 1984 00:00:00 +0530 Wed, 10 Feb 2010 12:29:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=27025 The Full Bench concluded that the Commissioner of Income-tax lacks jurisdiction to entertain a revision petition under section 264 of the Income-tax Act, 1961, when the order of the Appellate Assistant Commissioner is already under appeal before the Tribunal. The doctrine of merger was examined, emphasizing that the entire order merges into the appellate order, preventing the Commissioner's revisional jurisdiction. Additionally, the express bar under section 264(4) prohibits revision of orders subject to Tribunal appeals, irrespective of the relief sought or appealing party. The judgment stressed legal consistency and upheld the principle of merger, restricting the Commissioner's revision powers. Case-Laws Income Tax Fri, 26 Oct 1984 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=27025