Revision application under Section 264: remand for fresh merits review when alternative remedies were improperly relied upon.

Whether a revision under Section 264 may be denied solely because alternative remedies existed and whether appeal provisions applied to DDT-related treaty claims; the court found that rejecting revision on the mere availability of other remedies was untenable and that the appealed provision was inapplicable, directing fresh merits consideration of treaty relief and related tax computation by the Principal Commissioner.

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