https://www.taxtmi.com/caselaws?id=801574 Setting aside an assessment in revision and directing a fresh assessment renders the original assessment non-operative. An appeal founded solely on that superseded assessment becomes infructuous because it lacks a surviving basis, and parallel consideration could create conflicting findings or overlapping consequences. The fresh assessment is separately appealable and creates an independent cause of action. The assessee may therefore raise factual and legal challenges to additions, including the alleged cash-receipts addition, only in appellate proceedings concerning the operative fresh assessment, where the merits must be determined independently. en-us Mon, 28 Sep 2026 00:00:00 +0530 Fri, 23 Oct 2026 08:37:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801574 Setting aside an assessment in revision and directing a fresh assessment renders the original assessment non-operative. An appeal founded solely on that superseded assessment becomes infructuous because it lacks a surviving basis, and parallel consideration could create conflicting findings or overlapping consequences. The fresh assessment is separately appealable and creates an independent cause of action. The assessee may therefore raise factual and legal challenges to additions, including the alleged cash-receipts addition, only in appellate proceedings concerning the operative fresh assessment, where the merits must be determined independently. Case-Laws Income Tax Mon, 28 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801574