https://www.taxtmi.com/caselaws?id=145203 A summary rejection of a second appeal for failure to satisfy a preliminary pre-condition, such as payment of tax, is not a disposal on merits. In that situation, the appellate authority does not adjudicate the appeal or confirm the earlier order on merits, so the doctrine of merger does not operate as it would after substantive appellate determination. The earlier first appellate order therefore does not become immune from revision on that basis, and the Commissioner may still entertain a revision application unless another exception applies. The Commissioner's refusal to hear the revision was accordingly incorrect, and the matter was to be considered on merits. en-us Mon, 18 Jul 1966 00:00:00 +0530 Tue, 23 Apr 2013 10:52:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=145203 A summary rejection of a second appeal for failure to satisfy a preliminary pre-condition, such as payment of tax, is not a disposal on merits. In that situation, the appellate authority does not adjudicate the appeal or confirm the earlier order on merits, so the doctrine of merger does not operate as it would after substantive appellate determination. The earlier first appellate order therefore does not become immune from revision on that basis, and the Commissioner may still entertain a revision application unless another exception applies. The Commissioner's refusal to hear the revision was accordingly incorrect, and the matter was to be considered on merits. Case-Laws VAT and Sales Tax Mon, 18 Jul 1966 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=145203