The statutory right of appeal is order-specific: an assessee may...

The statutory right of appeal is order-specific: an assessee may challenge only the order that creates a grievance, and an intimation under section 143(1) and an assessment under section 143(3) operate independently. Where the later assessment merely accepts the income already determined under section 143(1) and makes no fresh addition or other adverse variation, no grievance arises from that assessment order and no appeal lies against it. The Tribunal rejected the doctrine of merger, holding that a challenge to adjustments made under section 143(1) must be taken against that order itself, not indirectly through an appeal against the later assessment. The dismissal of the appeal was therefore upheld.

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