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The ITAT held that when adjustments made under section 143(1) are incorporated into a subsequent assessment order under section 143(3) r/w/s 144B, the doctrine of merger applies, allowing the assessee to challenge such adjustments in an appeal against the assessment order. While dismissing Revenue's ground that CIT(A) erred in entertaining the appeal challenging section 143(1) adjustments, the Tribunal found that CIT(A) failed to provide reasoning for accepting the assessee's contentions without calling for a remand report. Regarding TDS credit, the ITAT directed the AO to allow additional TDS credit of 27,40,247 after verifying that corresponding income was offered to tax, requiring the assessee to file a reconciliation statement as evidence.
The ITAT held that when adjustments made under section 143(1) are incorporated into a subsequent assessment order under section 143(3) r/w/s 144B, the doctrine of merger applies, allowing the assessee to challenge such adjustments in an appeal against the assessment order. While dismissing Revenue's ground that CIT(A) erred in entertaining the appeal challenging section 143(1) adjustments, the Tribunal found that CIT(A) failed to provide reasoning for accepting the assessee's contentions without calling for a remand report. Regarding TDS credit, the ITAT directed the AO to allow additional TDS credit of 27,40,247 after verifying that corresponding income was offered to tax, requiring the assessee to file a reconciliation statement as evidence.
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