JUDGMENT Ashok Bhan, J.—The Revenue, being aggrieved by the order passed by the Income Tax Appellate Tribunal, Bangalore (for short, "the Tribunal"), in I. T. A. No. 950/Bang of 1992, for the assessment year 1988-89, has filed this appeal under Section 260A of the Income Tax Act, 1961 (for short, "the Act"). 2. The respondent-assesses filed its return of income for the year 1988-89. An order of assessment was passed in respect of the said assessment year. The assessing authority, for the purpose of computation of capital gains, had adopted the cost of the property at Rs. 80 lakhs as against Rs. 96.78 lakhs claimed by the assessee. The assessee, being aggrieved by the order of the assessing authority, filed an appeal before the Commissioner of Income Tax (Appeals). The Commissioner of Income Tax (Appeals) confirmed the orders of the assessing authority. 3. The Commissioner of Income Tax of the range, who has a co-ordinate jurisdiction as Commissioner of Income Tax (Appeals), initiated suo motu proceedings under Section 263 of the Act for revising the order of the assessing authority. 4. The respondent-assesses objected to the initiation of proceedings under Section 263 of the Act on the ground that the order of the assessing authority having merged with the order of the Commissioner of Income Tax (Appeals), the Commissioner of Income Tax, being of co-ordinate jurisdiction, did not have the jurisdiction to revise the order of the assessing authority. The Commissioner of Income Tax did not accept this contention and revised the assessment order. 5. The assessee, being aggrieved by the order of the Commissioner of Income Tax revising the order of assessment, filed an appeal before the Tribunal which has been accepted by the impugned order. The Tribunal has held that the order of the assessing authority having merged with the order of the Commissioner of Income Tax (Appeals), the Commissioner of Income Tax did not have the jurisdiction under Section 263 of the Act to revise the order of the assessing authority. It was observed in para. 2 of the order of the Tribunal as under : "In support of the said claim the order of the Commissioner of Income Tax (Appeals), dated May 3, 1991, was placed on our record in which para. 5 deals with the issue. In para. It was observed in para. 2 of the order of the Tribunal as under : "In support of the said claim the order of the Commissioner of Income Tax (Appeals), dated May 3, 1991, was placed on our record in which para. 5 deals with the issue. In para. 5, the Commissioner of Income Tax (Appeals) has noted that for the purpose of valuation of land on April 5, 1974, for computing the capital gains, the Assessing Officer had taken the value at Rs. 80 lakhs against the value of Rs. 96.79 lakhs shown by the assessee. He further noted that the Assessing Officer had determined the increase in the value of land from 1958 along with various documentary evidences and to the date of sale and on that basis, he had computed the value as on April 1, 1974, on a proportionate basis on a time scale and held that the approach of the Assessing Officer was rational and very fair and, accordingly, he declined to interfere. The objection of the Commissioner of Income Tax was that the value of Rs. 80 lakhs was also more and value should have been lesser." 6. According to the Revenue, the following substantial questions of law arise from the order of the Tribunal : "(a) Whether, on the facts and in the circumstances of the case, the Tribunal is correct in law in holding that the Commissioner of Income Tax had no power to revise the assessment as concluded in the respondent-assesses's case for the assessment year 1988-89 as the assessment had merged with the appellate order of the Commissioner of Income Tax (Appeals) ? (b) Whether, on the facts and in the circumstances of the case, the Tribunal is correct in law in holding that there is merger of the assessment of the appellate order and, therefore, there is a bar for the Commissioner to invoke the revisional proceedings under Section 263 of the Income Tax Act, 1961, in the respondent-assesses's case for the assessment year 1988-89 ?" 7. Admit. 8. The questions being interlinked and interrelated with each other, are taken up together for disposal. 9. It is evident from the reading of the order of the Tribunal that the order of the assessing authority regarding valuation of the property had merged with the order of the Commissioner of Income Tax (Appeals), dated May 3, 1991. Admit. 8. The questions being interlinked and interrelated with each other, are taken up together for disposal. 9. It is evident from the reading of the order of the Tribunal that the order of the assessing authority regarding valuation of the property had merged with the order of the Commissioner of Income Tax (Appeals), dated May 3, 1991. The order of the assessing authority having merged with the order of the Commissioner of Income Tax (Appeals), the Commissioner of Income Tax did not have the jurisdiction to revise the order of the assessing authority. Under Section 263 of the Act, the Commissioner has powers to revise orders of the assessing authority which are erroneous and prejudicial to the interest of the Revenue. He has no jurisdiction to revise orders of the Appellate Commissioner. The Tribunal was right in law in holding that the order of the assessing authority having merged with the appellate order of the Commissioner of Income Tax (Appeals) could not be revised by the Commissioner of Income Tax. The assumption of jurisdiction by the Commissioner of Income Tax to revise under Section 263 of the Act was bad in law. 10. We answer the questions in the affirmative, i.e., against the Revenue and in favour of the assessee.