Answer

1. F

   Facts

   Matters that were the subject of an appeal and decided in that appeal cannot be revised by the Commissioner under this power. Other matters in the same order can still be revised.

2. P

   Provisions and law

   • Sec 263, Income-tax Act 1961 (now Sec 377, Income-tax Act 2025)The Principal Commissioner or Commissioner can revise an assessment order that is erroneous and prejudicial to revenue, after giving a hearing, within 2 years from the end of the financial year of the order.
   • Sec 246A, Income-tax Act 1961 (now Sec 357, Income-tax Act 2025)Appeal to the Commissioner (Appeals).
3. A

   Analysis

   Check whether the issue in the show cause was raised and decided in your appeal. If yes, point to the appeal order and ground number. If the appeal covered other issues only, this defence does not help for the new issue. Attach the appeal order in your reply.

4. C

   Conclusion

   1. 1Compare the show cause issue with your appeal grounds.
   2. 2Get a copy of the appeal order.
   3. 3Point to the ground where it was decided.
   4. 4Attach the order to your reply.

General guidance from TaxSavvy’s library of money processes. Laws change; your Savvy confirms the answer on your exact case before anything is filed.