https://www.taxtmi.com/caselaws?id=21690 A merger-based challenge to action under section 154 of the Income-tax Act, 1961 could not be raised for the first time in reference jurisdiction because it had not been urged before the Tribunal and did not arise from the facts found in its order. The reference was confined to whether section 154 applied on the facts recorded, and a new contention outside that scope was not entertainable. The merger plea was rejected, and the referred question was answered in favour of the revenue and against the assessee. en-us Wed, 10 Jul 1991 00:00:00 +0530 Thu, 26 Nov 2009 17:26:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=21690 A merger-based challenge to action under section 154 of the Income-tax Act, 1961 could not be raised for the first time in reference jurisdiction because it had not been urged before the Tribunal and did not arise from the facts found in its order. The reference was confined to whether section 154 applied on the facts recorded, and a new contention outside that scope was not entertainable. The merger plea was rejected, and the referred question was answered in favour of the revenue and against the assessee. Case-Laws Income Tax Wed, 10 Jul 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=21690