https://www.taxtmi.com/caselaws?id=177655 Where the specific issue relating to the applicability of section 37(3A) was not raised before the appellate authority and was not considered by it, the assessment order did not merge with the appellate order on that point. On that factual basis, the doctrine of merger did not bar the Commissioner's revisional jurisdiction under section 263 of the Income-tax Act, 1961, and revision remained available on the unagitated issue. The answers were therefore against the assessee and in favour of the Revenue. en-us Mon, 19 Jan 1998 00:00:00 +0530 Thu, 14 Jan 2016 13:12:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=177655 Where the specific issue relating to the applicability of section 37(3A) was not raised before the appellate authority and was not considered by it, the assessment order did not merge with the appellate order on that point. On that factual basis, the doctrine of merger did not bar the Commissioner's revisional jurisdiction under section 263 of the Income-tax Act, 1961, and revision remained available on the unagitated issue. The answers were therefore against the assessee and in favour of the Revenue. Case-Laws Income Tax Mon, 19 Jan 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=177655