https://www.taxtmi.com/caselaws?id=28295 The court quashed the Commissioner's order dismissing a revision filed under section 264 of the Income Tax Act, emphasizing that the Commissioner erred in interpreting the jurisdiction exclusion clause in sub-clause (c) of subsection (4) of section 264. The court clarified that the dismissal of an appeal by the Commissioner (Appeals) does not automatically render the order the subject of an appeal. It highlighted the need for a substantive examination of orders on merits by higher authorities before deeming them appeal subjects. The judgment allowed the petition, set aside the Commissioner's order, and mandated a fresh decision on the revision's merits, issuing a certificate under Article 134A of the Constitution of India. en-us Mon, 14 Feb 1983 00:00:00 +0530 Sat, 20 Feb 2010 12:12:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=28295 The court quashed the Commissioner's order dismissing a revision filed under section 264 of the Income Tax Act, emphasizing that the Commissioner erred in interpreting the jurisdiction exclusion clause in sub-clause (c) of subsection (4) of section 264. The court clarified that the dismissal of an appeal by the Commissioner (Appeals) does not automatically render the order the subject of an appeal. It highlighted the need for a substantive examination of orders on merits by higher authorities before deeming them appeal subjects. The judgment allowed the petition, set aside the Commissioner's order, and mandated a fresh decision on the revision's merits, issuing a certificate under Article 134A of the Constitution of India. Case-Laws Income Tax Mon, 14 Feb 1983 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=28295