Section 264 as Alternative Remedy to Appeals: Validity of Revisions and Reopening Assessments under Income Tax Act.

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....Validity of Revision u/s 264 - Reopening of assessment u/s 147 - Whether revision under Section 264 of the 1961 Act is an alternate remedy to the remedy of regular appeal provided under Section 246 of the 1961 Act or not? - Remedy under Section 264 of the 1961 Act is an alternate remedy to the appeal under Section 246 of the 1961 Act. Once the petitioner chose to revoke the revisional jurisdiction, the authority was under obligation to decide the same in accordance with the provisions of Section 264 of the 1961 Act only - HC....