Doctrine of Merger in Income Tax Assessment: An Analysis of ITAT Chennai's Recent Judgment

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..... es and legal principles. One such principle that has gained significance over the years is the Doctrine of Merger. This doctrine becomes particularly relevant when appeals or revisions are filed against assessment orders. In a recent judgment by the Income Tax Appellate Tribunal (ITAT) Chennai, the doctrine of merger took center stage, and its implications are worth examining. The Case: Th .....

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..... action on certain groups. The assessment was eventually framed under Section 153C , making specific disallowances. Doctrine of Merger : The taxpayer contended that since the larger issues, including legal issues, were already pending before the Commissioner of Income Tax (Appeals) (CIT(A)) in the appeal against the order passed under Section 153C r.w.s 144, the doctrine of merger ap .....

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..... ed on the doctrine of merger and the legal precedents, the ITAT allowed the taxpayer's appeal, stating that the revision under Section 263 was bad-in-law and should be quashed. Conclusion: The doctrine of merger plays a crucial role in income tax assessments and appeals. In the case discussed above, it acted as a safeguard for the taxpayer's rights, preventing the revisory jur .....

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