https://www.taxtmi.com/caselaws?id=38810 The High Court held that the assessment order did not merge with the Commissioner's order under section 263 of the Income-tax Act, 1961. It was determined that the Commissioner's order was not time-barred under section 153(1)(a), ruling in favor of the revenue. The Court emphasized the independence of sections 153(1)(a) and 263, clarifying that the Commissioner's power under section 263 is separate and can only be exercised post the Income-tax Officer's order. The judgment favored the revenue, with both judges concurring, and no costs were awarded. en-us Wed, 08 Dec 1976 00:00:00 +0530 Fri, 09 Apr 2010 11:38:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38810 The High Court held that the assessment order did not merge with the Commissioner's order under section 263 of the Income-tax Act, 1961. It was determined that the Commissioner's order was not time-barred under section 153(1)(a), ruling in favor of the revenue. The Court emphasized the independence of sections 153(1)(a) and 263, clarifying that the Commissioner's power under section 263 is separate and can only be exercised post the Income-tax Officer's order. The judgment favored the revenue, with both judges concurring, and no costs were awarded. Case-Laws Income Tax Wed, 08 Dec 1976 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38810