https://www.taxtmi.com/news?id=1188 The doctrine of merger cannot be applied mechanically to extinguish arguments or rights that were never contested in the earlier proceeding; where an adjudicating authority disallowed two deductions and allowed six, and an appeal to the Tribunal challenged only the two disallowances, the Tribunal's reliance on merger to preclude reconsideration of the six allowed deductions was incorrect because those deductions were not litigated and could only have been contested by the Revenue. en-us Tue, 13 Jul 2010 16:32:00 +0530 Tue, 13 Jul 2010 16:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/news?id=1188 The doctrine of merger cannot be applied mechanically to extinguish arguments or rights that were never contested in the earlier proceeding; where an adjudicating authority disallowed two deductions and allowed six, and an appeal to the Tribunal challenged only the two disallowances, the Tribunal's reliance on merger to preclude reconsideration of the six allowed deductions was incorrect because those deductions were not litigated and could only have been contested by the Revenue. News - Tue, 13 Jul 2010 16:32:00 +0530 https://www.taxtmi.com/news?id=1188