https://www.taxtmi.com/caselaws?id=789020 Section 263 revision cannot be invoked where the reassessment order, or the issue forming part of it, is already the subject of a pending appeal before the Commissioner (Appeals). Explanation 1(c) to section 263(1) allows revision only for matters not considered and decided in appeal; it does not permit revision of an issue that is already carried in appellate proceedings. As the same dispute concerning the sale of shares and the reassessment order was pending in appeal, the Principal Commissioner lacked jurisdiction to revise the order, and the revision was quashed. en-us Tue, 24 Feb 2026 00:00:00 +0530 Thu, 02 Apr 2026 08:50:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789020 Section 263 revision cannot be invoked where the reassessment order, or the issue forming part of it, is already the subject of a pending appeal before the Commissioner (Appeals). Explanation 1(c) to section 263(1) allows revision only for matters not considered and decided in appeal; it does not permit revision of an issue that is already carried in appellate proceedings. As the same dispute concerning the sale of shares and the reassessment order was pending in appeal, the Principal Commissioner lacked jurisdiction to revise the order, and the revision was quashed. Case-Laws Income Tax Tue, 24 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789020