In appeal before the CIT (A) was  whether the assessee was  entitled to deduction under section 80I on the goods manufactured and exported ,which was allowed .   An appeal was filed by the Revenue before the Tribunal and the assessee filed cross-objections. In the meantime, a notice under section 263 was issued on the ground that the Assessing Officer had erred in allowing deduction under section 80-I on the duty drawback received on manufactured goods. The contention of the assessee that the issue was the subject-matter of appeal before the Commissioner (Appeals) was rejected. The assessment order was set aside directing the Assessing Officer to withdraw the relief allowed under section 80-I on the duty drawback on the goods manufactured and exported. The appeal filed against the revision order was dismissed by the Tribunal. On appeal dismissing the appeal, that the issue whether the assessee was entitled to deduction under section 80-I on duty drawback with regard to goods manufactured and exported was neither considered nor decided in appeal. The Tribunal had rightly held that the issue whether deduction under section 80-I was available on duty draw-back on manufactured goods was never specifically dealt with in the appeal. The issue taken up in revision was not subject-matter of the appeal. The Tribunal rightly dismissed the appeal filed by the assessee against the revision order.( AY.1989-90)