https://www.taxtmi.com/caselaws?id=154177 The doctrine of merger applies only to the portion of an assessment order actually considered and decided in appeal; any untouched part continues to subsist in the original order. Revision under section 39(2) may therefore reach only that surviving portion, and the three-year limitation is computed from the assessment order for that untouched subject-matter. On the facts, the appellate authority did not decide the exemption on the disputed turnover, so that part had not merged. The Commissioner was consequently barred from revising the exempt turnover after expiry of the statutory period. en-us Tue, 15 Mar 1983 00:00:00 +0530 Fri, 09 Aug 2013 17:26:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=154177 The doctrine of merger applies only to the portion of an assessment order actually considered and decided in appeal; any untouched part continues to subsist in the original order. Revision under section 39(2) may therefore reach only that surviving portion, and the three-year limitation is computed from the assessment order for that untouched subject-matter. On the facts, the appellate authority did not decide the exemption on the disputed turnover, so that part had not merged. The Commissioner was consequently barred from revising the exempt turnover after expiry of the statutory period. Case-Laws VAT and Sales Tax Tue, 15 Mar 1983 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=154177