https://www.taxtmi.com/caselaws?id=59916 The Tribunal upheld the Commissioner's order under Section 263, rejecting the assessee's appeal. The Commissioner was deemed competent to revise the ITO's assessment order concerning the undisclosed income from jewellery. The doctrine of merger did not apply as the ITO had not considered this issue in the regular assessment, and the AAC could not enhance the income based on new sources not addressed by the ITO. The Tribunal emphasized the distinction between proceedings under Sections 132 and 143 of the Income-tax Act, supporting the Commissioner's intervention under Section 263. en-us Tue, 13 Apr 1982 00:00:00 +0530 Sat, 01 Jan 2011 17:57:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59916 The Tribunal upheld the Commissioner's order under Section 263, rejecting the assessee's appeal. The Commissioner was deemed competent to revise the ITO's assessment order concerning the undisclosed income from jewellery. The doctrine of merger did not apply as the ITO had not considered this issue in the regular assessment, and the AAC could not enhance the income based on new sources not addressed by the ITO. The Tribunal emphasized the distinction between proceedings under Sections 132 and 143 of the Income-tax Act, supporting the Commissioner's intervention under Section 263. Case-Laws Income Tax Tue, 13 Apr 1982 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59916