https://www.taxtmi.com/caselaws?id=153066 The doctrine of merger applies only to the matters actually raised and decided in appeal. Where no penalty under section 43(1) of the M.P. General Sales Tax Act, 1958 was imposed by either the assessing authority or the first appellate authority, and the appellate order dealt only with other issues, the original assessment order did not merge on the unconsidered penalty issue. Limitation for revision under section 39(2) therefore ran from the date of the assessment order, not the appellate order, and the revisional proceeding was held to be time-barred. en-us Fri, 19 Sep 1980 00:00:00 +0530 Tue, 16 Jul 2013 18:18:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=153066 The doctrine of merger applies only to the matters actually raised and decided in appeal. Where no penalty under section 43(1) of the M.P. General Sales Tax Act, 1958 was imposed by either the assessing authority or the first appellate authority, and the appellate order dealt only with other issues, the original assessment order did not merge on the unconsidered penalty issue. Limitation for revision under section 39(2) therefore ran from the date of the assessment order, not the appellate order, and the revisional proceeding was held to be time-barred. Case-Laws VAT and Sales Tax Fri, 19 Sep 1980 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=153066