Merger of processing intimation into scrutiny assessment renders the earlier appeal infructuous and unsustainable.

An intimation under section 143(1)(a) loses independent existence once the same adjustments are reconsidered and deleted in a regular scrutiny assessment under section 143(3). The later assessment order supplants the earlier processing order by merger, so no live dispute remains on the original adjustments. As a result, an appeal directed only against the intimation becomes infructuous and cannot survive for adjudication.

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Issues: Whether an appeal against an intimation under section 143(1)(a) of the Income-tax Act, 1961 survives after the same adjustments are reconsidered and deleted in the scrutiny assessment under section 143(3) of the Income-tax Act, 1961.

Analysis: The additions made in the intimation were subsequently taken up in the scrutiny proceedings, the rectification application was considered, and the assessing authority granted relief in the draft and final assessment orders. Once the regular assessment under section 143(3) came to be made, the earlier intimation under section 143(1)(a) ceased to have independent existence and merged with the scrutiny assessment. In that situation, the appeal directed against the intimation no longer had a live cause for adjudication and became infructuous.

Conclusion: The appeal against the intimation under section 143(1)(a) was infructuous after merger with the scrutiny assessment, and the challenge could not survive.

Final Conclusion: The decision leaves no subsisting dispute on the adjustments made in the intimation, as the later regular assessment displaced the earlier processing order.

Ratio Decidendi: An intimation under section 143(1)(a) loses independent existence and any appeal against it becomes infructuous once the same matter is subsumed in a subsequent regular assessment under section 143(3).

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