https://www.taxtmi.com/caselaws?id=36808 In income-tax rectification, limitation under section 154 is computed from the date of the order sought to be amended. Where an assessee appeals only against part of an assessment and the appellate authority does not consider the remaining portion, that untouched part retains its independent existence. The doctrine of merger is therefore partial, not universal, and applies only to the matters actually dealt with in appeal. On that footing, the original assessment order remained the relevant order for limitation in respect of the rebate not affected by the appellate order, making the rectification time-barred. en-us Tue, 27 Feb 1979 00:00:00 +0530 Wed, 24 Mar 2010 16:26:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=36808 In income-tax rectification, limitation under section 154 is computed from the date of the order sought to be amended. Where an assessee appeals only against part of an assessment and the appellate authority does not consider the remaining portion, that untouched part retains its independent existence. The doctrine of merger is therefore partial, not universal, and applies only to the matters actually dealt with in appeal. On that footing, the original assessment order remained the relevant order for limitation in respect of the rebate not affected by the appellate order, making the rectification time-barred. Case-Laws Income Tax Tue, 27 Feb 1979 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=36808