Merger of section 143(1) processing into later scrutiny assessment rendered the appeal infructuous and ended the challenge.

Where a scrutiny assessment under section 143(3) had already been completed for the same assessment year, the earlier processing order under section 143(1) was treated as merged into the later assessment order. The appeal against the processing order therefore ceased to have independent survival and became infructuous. The merits of the additions and disallowances were not examined, and relief followed on this jurisdictional and procedural ground without adjudication of the substantive issues.

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Issues: Whether the appeal against the processing order under section 143(1) survived after a subsequent scrutiny assessment under section 143(3) was passed for the same assessment year.

Analysis: The subsequent scrutiny assessment covered the same assessment year and had already been completed before the appeal was decided. In these circumstances, the processing order under section 143(1) was treated as merged with the later assessment order under section 143(3). As a result, the challenge to the processing and resulting adjustments ceased to have independent survival. The merits of the additions and disallowances were not examined.

Conclusion: The appeal against the section 143(1) processing order had become infructuous and the assessee succeeded on this jurisdictional and procedural ground.

Final Conclusion: The impugned appellate order was set aside and the assessee obtained relief without any adjudication on the substantive additions.

Ratio Decidendi: Where a subsequent scrutiny assessment under section 143(3) has already been made for the same assessment year, the earlier processing order under section 143(1) merges into it and the appeal against the processing order becomes infructuous.

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