Revisional relief for double taxation requires merits review where the same income is assessed in two different years.

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....Section 264 provides beneficial and remedial revisional relief against over-assessment, including errors in a taxpayer's return. Relief is not dependent on filing a revised return within the prescribed time or on whether the error arose from the taxpayer's voluntary action or a departmental order. Taxing the same income in two assessment years can create an over-assessment where the combined effect of the relevant orders results in double taxation. A revisional authority must examine the claim and reconciliations on their merits rather than reject relief solely because an intimation accepted the returned income in isolation.....