Condonation of Delay: Tribunal directed condonation where rectification proceedings were pursued, ordering merits adjudication after opportunity to be...
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Section 143(1)(a) intimation lost its independent existence after the Assessing Officer reconsidered the same adjustments in scrutiny assessment under section 143(3) and granted relief on the rectification request. Applying the merger principle, the Tribunal held that the appeal against the intimation had become infructuous, and once that appeal was infructuous, the Revenue's further appeal against the first appellate order in the same matter was also infructuous. The Revenue's appeal was therefore dismissed on that basis.
Section 143(1)(a) intimation lost its independent existence after the Assessing Officer reconsidered the same adjustments in scrutiny assessment under section 143(3) and granted relief on the rectification request. Applying the merger principle, the Tribunal held that the appeal against the intimation had become infructuous, and once that appeal was infructuous, the Revenue's further appeal against the first appellate order in the same matter was also infructuous. The Revenue's appeal was therefore dismissed on that basis.
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