https://www.taxtmi.com/caselaws?id=801097 Section 264 revisional jurisdiction may consider a new question or point of law only where it arises from facts already available in the assessment record. It cannot admit a fresh claim requiring facts outside that record, because doing so would effectively allow revision of the return after the statutory deadline. The Tribunal's appellate powers do not expand either the revisional authority's powers or the assessing authority's jurisdiction to entertain an otherwise time-barred claim. Consequently, a fresh claim not made through a timely revised return cannot be raised in revision. en-us Thu, 08 Oct 2026 00:00:00 +0530 Thu, 15 Oct 2026 05:44:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801097 Section 264 revisional jurisdiction may consider a new question or point of law only where it arises from facts already available in the assessment record. It cannot admit a fresh claim requiring facts outside that record, because doing so would effectively allow revision of the return after the statutory deadline. The Tribunal's appellate powers do not expand either the revisional authority's powers or the assessing authority's jurisdiction to entertain an otherwise time-barred claim. Consequently, a fresh claim not made through a timely revised return cannot be raised in revision. Case-Laws Income Tax Thu, 08 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801097