https://www.taxtmi.com/caselaws?id=207739 The doctrine of merger applies only to the subject matter actually challenged in appeal, so a limited appeal confined to interest and penalty does not cause the entire assessment order to merge in the appellate order. The unchallenged parts of the assessment retain their separate identity for limitation purposes under the revisional provision. As a result, revision time ran from communication of the original assessment order, and a revisional order passed beyond the statutory period was barred. The Tribunal's view that the revision was time-barred was therefore correct. en-us Thu, 17 Nov 2011 00:00:00 +0530 Mon, 04 Sep 2017 11:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=207739 The doctrine of merger applies only to the subject matter actually challenged in appeal, so a limited appeal confined to interest and penalty does not cause the entire assessment order to merge in the appellate order. The unchallenged parts of the assessment retain their separate identity for limitation purposes under the revisional provision. As a result, revision time ran from communication of the original assessment order, and a revisional order passed beyond the statutory period was barred. The Tribunal's view that the revision was time-barred was therefore correct. Case-Laws VAT and Sales Tax Thu, 17 Nov 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=207739