https://www.taxtmi.com/caselaws?id=27875 The doctrine of merger is not universal and applies only to the portion of an assessment actually taken up and decided in appeal. Where the appeal under the Estate Duty Act was confined to valuation of specified properties, the appellate authority's order did not absorb the entire original assessment. The original order therefore continued to subsist for matters outside the appellate decision, and rectification under section 61 remained available in respect of those matters. The rectification notice did not seek to disturb the issues already decided on appeal, so the challenge based on complete merger failed. en-us Tue, 15 May 1984 00:00:00 +0530 Tue, 16 Feb 2010 15:44:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=27875 The doctrine of merger is not universal and applies only to the portion of an assessment actually taken up and decided in appeal. Where the appeal under the Estate Duty Act was confined to valuation of specified properties, the appellate authority's order did not absorb the entire original assessment. The original order therefore continued to subsist for matters outside the appellate decision, and rectification under section 61 remained available in respect of those matters. The rectification notice did not seek to disturb the issues already decided on appeal, so the challenge based on complete merger failed. Case-Laws Income Tax Tue, 15 May 1984 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=27875