https://www.taxtmi.com/caselaws?id=22919 A notification granting exemption from purchase tax took effect only when it was published and made available to the public, not merely on the date it was issued; because publication occurred on 3 April 1979, the exemption operated within the relevant accounting year and the Revenue's section 41(1) claim failed. In contrast, the doctrine of merger in income-tax proceedings applies only to issues actually considered and decided in appeal, so a point not raised before the first appellate authority remained open to revision under section 263. The assessee succeeded on the first issue and the Revenue on the second. en-us Tue, 31 Jul 1990 00:00:00 +0530 Tue, 15 Dec 2009 13:23:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=22919 A notification granting exemption from purchase tax took effect only when it was published and made available to the public, not merely on the date it was issued; because publication occurred on 3 April 1979, the exemption operated within the relevant accounting year and the Revenue's section 41(1) claim failed. In contrast, the doctrine of merger in income-tax proceedings applies only to issues actually considered and decided in appeal, so a point not raised before the first appellate authority remained open to revision under section 263. The assessee succeeded on the first issue and the Revenue on the second. Case-Laws Income Tax Tue, 31 Jul 1990 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=22919