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    <title>2025 (9) TMI 930 - BOMBAY HIGH COURT</title>
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    <description>The merger doctrine applied where an assessee appealed only against the penalty and interest component of a composite assessment-cum-penalty order; once that component was set aside in appeal, the original order stood absorbed to that extent. Revisional power under Section 57(1)(a) was confined to orders of subordinate authorities and could not be exercised over an order of a coordinate or coequal authority, so the revision was invalid. Rectification under Section 62 was proper because the Tribunal had overlooked this jurisdictional defect and binding precedent, which amounted to an error apparent from the record. All issues were resolved in favour of the assessee.</description>
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      <title>2025 (9) TMI 930 - BOMBAY HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=778441</link>
      <description>The merger doctrine applied where an assessee appealed only against the penalty and interest component of a composite assessment-cum-penalty order; once that component was set aside in appeal, the original order stood absorbed to that extent. Revisional power under Section 57(1)(a) was confined to orders of subordinate authorities and could not be exercised over an order of a coordinate or coequal authority, so the revision was invalid. Rectification under Section 62 was proper because the Tribunal had overlooked this jurisdictional defect and binding precedent, which amounted to an error apparent from the record. All issues were resolved in favour of the assessee.</description>
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