https://www.taxtmi.com/caselaws?id=783631 The dominant issue was whether an intimation under s.143(1)(a) merged into the subsequent regular assessment under s.143(3), thereby foreclosing consideration of objections to prima facie adjustments (disallowance under s.35(1) and denial of MAT credit) raised through a pending s.154 rectification application. The Tribunal held that merger does not apply where the AO, while completing s.143(3), merely adopted the income as per s.143(1) intimation without adjudicating the assessee's specific grievance or the s.154 request; such non-consideration indicates the intimation remained independently challengeable. Consequently, the matter was remitted to the first appellate authority to adjudicate the assessee's grievance afresh; the appeal was allowed for statistical purposes. en-us Wed, 10 Dec 2025 00:00:00 +0530 Fri, 19 Dec 2025 08:30:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783631 The dominant issue was whether an intimation under s.143(1)(a) merged into the subsequent regular assessment under s.143(3), thereby foreclosing consideration of objections to prima facie adjustments (disallowance under s.35(1) and denial of MAT credit) raised through a pending s.154 rectification application. The Tribunal held that merger does not apply where the AO, while completing s.143(3), merely adopted the income as per s.143(1) intimation without adjudicating the assessee's specific grievance or the s.154 request; such non-consideration indicates the intimation remained independently challengeable. Consequently, the matter was remitted to the first appellate authority to adjudicate the assessee's grievance afresh; the appeal was allowed for statistical purposes. Case-Laws Income Tax Wed, 10 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783631