https://www.taxtmi.com/caselaws?id=150681 An appeal dismissed solely as time-barred does not produce merger, because there is no effective appellate adjudication on the merits of the assessment. The doctrine of merger is not universal and depends on the nature and scope of the appellate or revisional order. The text also notes that, where statutory reference proceedings fail to give effective relief in the special facts of the case, the High Court may entertain a writ petition under Article 226 and quash the assessment orders. In such circumstances, the Court may set aside the assessments and permit fresh assessments in accordance with law. en-us Mon, 26 Nov 1973 00:00:00 +0530 Tue, 21 May 2013 12:59:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=150681 An appeal dismissed solely as time-barred does not produce merger, because there is no effective appellate adjudication on the merits of the assessment. The doctrine of merger is not universal and depends on the nature and scope of the appellate or revisional order. The text also notes that, where statutory reference proceedings fail to give effective relief in the special facts of the case, the High Court may entertain a writ petition under Article 226 and quash the assessment orders. In such circumstances, the Court may set aside the assessments and permit fresh assessments in accordance with law. Case-Laws VAT and Sales Tax Mon, 26 Nov 1973 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=150681