https://www.taxtmi.com/caselaws?id=179175 Reassessment under section 147 on arrears of depreciation and revaluation reserve in computing book profit under section 115JB did not merge with a later revision under section 263 aimed at alleged failure to disallow exempt dividend income under clause (f) of Explanation 1 to section 115JB. Because the reassessment and revision concerned distinct subject matter, the doctrine of merger did not shift the limitation base to the reassessment order. Limitation under section 263(2) therefore had to run from the original assessment order, and the revisionary order was time-barred and unsustainable. en-us Wed, 06 Apr 2011 00:00:00 +0530 Mon, 22 Feb 2016 16:46:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=179175 Reassessment under section 147 on arrears of depreciation and revaluation reserve in computing book profit under section 115JB did not merge with a later revision under section 263 aimed at alleged failure to disallow exempt dividend income under clause (f) of Explanation 1 to section 115JB. Because the reassessment and revision concerned distinct subject matter, the doctrine of merger did not shift the limitation base to the reassessment order. Limitation under section 263(2) therefore had to run from the original assessment order, and the revisionary order was time-barred and unsustainable. Case-Laws Income Tax Wed, 06 Apr 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=179175