COMMISSIONER OF INCOME TAX, BHOPAL vs RALSON INDUSTRIES LTD.

The Supreme Court interpreted Sections 154 and 263 of the Income Tax Act, holding that the Commissioner of Income Tax lacked jurisdiction to revise the assessment order after a rectification notice was issued under Section 154. The Court affirmed the Income Tax Appellate Tribunal's decision that the issue of excess deductions under Sections 80HH and 80-I was merged with the order under Section 154, thus barring the Commissioner from invoking Section 263. The appeal was dismissed, upholding the Tribunal's ruling.