https://www.taxtmi.com/caselaws?id=66520 The doctrine of merger under section 263 is confined to matters actually considered in appeal; where the excise duty provision was not examined by the appellate authorities, revision was not barred on that point. A provision for additional excise duty raised through show-cause notices was treated as an accrued liability under mercantile accounting because statutory liability arises on manufacture and clearance of excisable goods even if quantification is disputed. On that basis, the provision was allowable and the assessment was not erroneous or prejudicial to the revenue on this issue. The revisionary order could not be sustained. en-us Tue, 23 May 1989 00:00:00 +0530 Sat, 26 Feb 2011 13:01:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=66520 The doctrine of merger under section 263 is confined to matters actually considered in appeal; where the excise duty provision was not examined by the appellate authorities, revision was not barred on that point. A provision for additional excise duty raised through show-cause notices was treated as an accrued liability under mercantile accounting because statutory liability arises on manufacture and clearance of excisable goods even if quantification is disputed. On that basis, the provision was allowable and the assessment was not erroneous or prejudicial to the revenue on this issue. The revisionary order could not be sustained. Case-Laws Income Tax Tue, 23 May 1989 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=66520