https://www.taxtmi.com/caselaws?id=25833 The court held that the assessee was not entitled to the development rebate as they had not complied with the mandatory requirement of creating a reserve fund as per section 34(3)(a) of the Income-tax Act, 1961. Additionally, the Income-tax Officer was deemed competent to rectify the order under section 154, as the matter concerning the development rebate was not part of the appeal before the Appellate Assistant Commissioner. The court clarified the doctrine of merger, stating that only issues considered and decided by the appellate authority merge with the original order. Ultimately, the court ruled against the assessee and in favor of the Revenue. en-us Fri, 01 Aug 1986 00:00:00 +0530 Mon, 01 Feb 2010 12:07:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=25833 The court held that the assessee was not entitled to the development rebate as they had not complied with the mandatory requirement of creating a reserve fund as per section 34(3)(a) of the Income-tax Act, 1961. Additionally, the Income-tax Officer was deemed competent to rectify the order under section 154, as the matter concerning the development rebate was not part of the appeal before the Appellate Assistant Commissioner. The court clarified the doctrine of merger, stating that only issues considered and decided by the appellate authority merge with the original order. Ultimately, the court ruled against the assessee and in favor of the Revenue. Case-Laws Income Tax Fri, 01 Aug 1986 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=25833