JUDGMENT When this appeal was placed before us earlier, in all fairness, our attention was invited to order passed by Income-tax Appellate Tribunal on June 4, 2014, on Miscellaneous Application No. 170/Mum/2013. present appeal under section 260A of Income-tax Act, 1961 ("the IT Act"), at instance of State Bank of India (SBI) challenges earlier order of Tribunal dated June 6, 2012, disposing of Income Tax Appeal No. 3145/Mum/2009, for assessment year 2006-07. During pendency of this appeal, Tribunal has passed order on miscellaneous application and, therefore, Mr. Jasani had sought time to take instructions as to whether State Bank of India is ready and willing for disposal of present appeal in light of order passed by Tribunal subsequently and on above miscellaneous application. However, Mr. Jasani submits that by order dated June 4, 2014, what Tribunal has done is to revive Income Tax Appeal No. 3145 of 2009 for hearing afresh on merits in relation to withdrawal of deduction under section 36(1)(viia) of Income-tax Act. That is in relation to provisions on standard assets. Meaning thereby, Tribunal has not allowed SBI, assessee before us, to argue revived appeal on all points and grounds including invocability of section 263 of Income-tax Act by Commissioner. In other words, Tribunal will now hear appeal on merits and not allow ground challenging exercise of powers under section 263 of Income- tax Act by Commissioner to be raised after revival of appeal. In that regard, Mr. Chhotaray submits that there is no challenge to order passed on miscellaneous application. Further, in miscellaneous application, SBI did not seek revival of appeal so as to challenge order passed by Commissioner under section 263 of Income-tax Act. In these circumstances, limited order as passed by Tribunal and further to this appeal can safely be utilised to dispose of present appeal. That is rendered infructuous. We have, with assistance of Mr. Jasani and Mr. Chhotaray, perused order passed by Tribunal on June 4, 2014, on Miscellaneous Application No. 170/Mum/2013. Mr. Jasani has been fair enough to place, copy of application as also order, on record and which we marked as "X" for identification collectively. Both copies have been provided in advance to Revenue's advocate Mr. Chhotaray. application was filed by assessee bringing to notice of Tribunal that ground in respect of withdrawal of deduction under section 36(1)(viia) of Income-tax Act of Rs. 405,17,20,944 in relation to standard assets was raised in memo of appeal. Tribunal's attention was invited to paragraph 3 of its earlier order dated June 6, 2012, from which, this miscellaneous application arose. Tribunal has merely followed its order for preceding assessment year 2005-06 and upheld order passed by Commissioner of Income-tax, which is complaint. However, what Tribunal was called upon to consider in miscellaneous application is that Commissioner in assessment year 2005-06 has not decided ground on merits but directed Assessing Officer to redo assessment after giving sufficient opportunity of being heard to assessee. However, in assessment year 2006-07, Commissioner of Income-tax has decided ground on merits. Hence, this part of Tribunal's order is vitiated by error of law apparent on face of record. We have seen that prayer in miscellaneous application as well. However, upon perusal of order passed by Tribunal, argument of assessee's advocate has been noted that in earlier order passed under section 263 of Income-tax Act for assessment year 2005- 06, Commissioner set aside assessment on all points raised by him and directed Assessing Officer to redo it. order of Commissioner was confirmed by Tribunal on March 30, 2012, in Income Tax Appeal No. 4288/Mum/2010 on ground that no inquiry or query was raised by Assessing Officer on issues raised by Commissioner in its order dated March 25, 2010, and, therefore, assessment order was erroneous in so far as it is prejudicial to interests of Revenue. argument that Tribunal has not gone into merits was, therefore, noted in paragraph 3. In paragraph 4, Departmental representative's objection has been noted. Thereafter, from 4, Departmental representative's objection has been noted. Thereafter, from paragraph 5 onwards, Tribunal assigns reasons and in paragraph 9, it specifically holds that counsel appearing for assessee contended that facts and circumstances in which earlier order was rendered were no longer applicable for reason that in this year Commissioner has passed order after discussing merits and therefore, earlier Tribunal's order will not apply in this year. Tribunal proceeds to reject this argument and, thereafter, directs revival of appeal only for purpose of raising ground of withdrawal of deduction under section 36(1)(viia) of Income-tax Act. We are not happy in manner in which Tribunal has decided miscellaneous application. If Tribunal was required to devote so much time for assigning reasons in more than five paragraphs in lengthy eight page order on miscellaneous application so as to correct obvious mistake by exercising powers under section 254(2) of Income-tax Act, then interest of justice would have been subserved and better had Tribunal revived entire appeal and not partially. It may be that Tribunal does not find sufficient ground to uphold objection raised by assessee to exercise of powers under section 263 of Income-tax Act by Commissioner, however, it was not necessary and in given facts and circumstances to endorse earlier conclusions. If there was mistake and in this case with regard to claim of deduction running into Rs. 405,17,20,944, then, we do not think that Tribunal was justified in directing partial revival of appeal. Now, let appeal be heard on all grounds as were raised originally. Tribunal should pass fresh order not only in relation to objection raised by assessee to exercise of powers under section 263 of Income-tax Act but on merits of claim as well. Merely because such opportunity is given by us does not mean that Tribunal is obliged to uphold any of grounds. It is only partial revival of appeal and in manner done by Tribunal which has forced us to take this unusual step. We do not think that interest of justice and equity is served by nonconsideration of vital materials by last fact finding authority, namely, Income-tax Appellate Tribunal. That Tribunal was required to recall its earlier orders and for reasons which have been assigned by it would indicate that it failed to apply its mind at initial stage to grounds raised in appeal and in their entirety. It omitted from consideration crucial documentary material as well. In such circumstances, such partial revival of appeal would not meet ends of justice. We modify order passed on miscellaneous application and direct that appeal shall now be heard on its own merits and in accordance with law, permitting assessee to raise all grounds that are to be found in memo of appeal. Tribunal shall apply its mind afresh to contentions raised by both sides and uninfluenced by its prior observations and conclusions and dispose of appeal on its own merits and in accordance with law. This direction issued by us in exercise of our further appellate and inherent powers should serve as reminder to Tribunal that matters of vital importance affecting interest of public should not be disposed of in light hearted or casual manner. record must be perused in its entirety and properly and minutely. That is function and which judicial body is required to perform and oblige to carry out as well. In these circumstances and unsatisfactory and unhappy manner in which miscellaneous application has been dealt with and decided that we have directed revival of appeal. We express no opinion on rival contentions and appeal shall be decided by Tribunal on its own merits and in accordance with law, without being influenced by any observations. We further clarify that this order passed today does not oblige Tribunal to either allow appeal in entirety or partially. All courses and open in law can be adopted by Tribunal. This appeal is accordingly disposed of. No costs. *** State Bank of India v. Deputy Commissioner of Income-tax