https://www.taxtmi.com/caselaws?id=17582 The doctrine of merger does not extend to assessment findings that were not actually challenged in appeal before the appellate authority. Only matters carried in appeal merge into the appellate order, so favourable portions of the assessment left unagitated remain open to revision. On that basis, the Commissioner could validly invoke revisional jurisdiction under section 263 to examine whether those untouched parts were erroneous and prejudicial to the Revenue, and the revisional direction for withdrawal or recomputation was upheld. en-us Mon, 17 Feb 1997 00:00:00 +0530 Wed, 23 Sep 2009 15:00:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=17582 The doctrine of merger does not extend to assessment findings that were not actually challenged in appeal before the appellate authority. Only matters carried in appeal merge into the appellate order, so favourable portions of the assessment left unagitated remain open to revision. On that basis, the Commissioner could validly invoke revisional jurisdiction under section 263 to examine whether those untouched parts were erroneous and prejudicial to the Revenue, and the revisional direction for withdrawal or recomputation was upheld. Case-Laws Income Tax Mon, 17 Feb 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=17582