TMI BlogAssessee Cannot Challenge Assessment Order in Collateral Proceedings; Tribunal Misapplies Doctrine of Merger.Refund claim - assessment order not challenged - Once an assessee choses not to file an appeal, then, he cannot challenge the same, in a collateral proceedings - the Tribunal has applied the Doctrine of Merger, which is not applicable to the facts of this case. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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