https://www.taxtmi.com/caselaws?id=163147 The doctrine of merger applies only to the subject-matter actually considered in appeal and does not bar reassessment of escaped turnover discovered later. Reassessment under rule 12(8) is permissible where turnover escaped assessment or was under-assessed, provided reasons are recorded and limitation is observed; the reassessment notice was therefore upheld. Fresh material not before the assessing officer cannot be relied on by the appellate authority to enhance the assessment, because enhancement must proceed on the assessment record and matters actually in issue. The Commissioner likewise cannot use revisional power to introduce new factual material outside the original record. en-us Fri, 16 May 2008 00:00:00 +0530 Mon, 08 Dec 2014 12:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=163147 The doctrine of merger applies only to the subject-matter actually considered in appeal and does not bar reassessment of escaped turnover discovered later. Reassessment under rule 12(8) is permissible where turnover escaped assessment or was under-assessed, provided reasons are recorded and limitation is observed; the reassessment notice was therefore upheld. Fresh material not before the assessing officer cannot be relied on by the appellate authority to enhance the assessment, because enhancement must proceed on the assessment record and matters actually in issue. The Commissioner likewise cannot use revisional power to introduce new factual material outside the original record. Case-Laws VAT and Sales Tax Fri, 16 May 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=163147