Merger of intimation with scrutiny assessment rendered the separate appeal infructuous on the same section 80JJAA deduction claim.

An intimation under section 143(1) did not survive independently once a subsequent scrutiny assessment under section 143(3) covered the same deduction claim under section 80JJAA. Because the later assessment addressed the identical subject-matter, the earlier intimation was treated as merged with the scrutiny assessment. The appeal against the intimation was therefore inoperative and infructuous, and the substantive section 80JJAA controversy was not separately adjudicated in this appeal.

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Issues: Whether the intimation under section 143(1) of the Income-tax Act, 1961 survived independently after the subsequent scrutiny assessment under section 143(3), and whether the appeal against the intimation had become infructuous by reason of merger.

Analysis: The adjustment made in the intimation under section 143(1) and the disallowance made in the scrutiny assessment under section 143(3) concerned the same deduction claim under section 80JJAA. The Court noted that the later assessment dealt with the same subject-matter, and therefore the earlier intimation did not survive as an independent operative order. In view of the identity of the issue in both proceedings, the intimation was treated as merged with the scrutiny assessment. As the substantive controversy over section 80JJAA was already pending in the appeal against the assessment order, the present appeal could not be separately adjudicated on merits.

Conclusion: The appeal against the intimation under section 143(1) was held to be inoperative and infructuous; the related substantive grounds were not adjudicated in this appeal.

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