https://www.taxtmi.com/caselaws?id=56271 An assessment under section 143(3) was treated as a composite order, and the doctrine of merger was applied by reference to the appellate authority's powers under section 251, including enhancement jurisdiction. The Tribunal held that merger depends on the full scope of matters the appellate authority could lawfully examine, not only the issues actually considered. Accordingly, once the assessment had merged in the appellate order, the Commissioner could not invoke section 263 to revise matters within that appellate jurisdiction. The revisional order was set aside and the assessee's appeal succeeded. en-us Tue, 25 May 1982 00:00:00 +0530 Thu, 02 Dec 2010 17:29:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=56271 An assessment under section 143(3) was treated as a composite order, and the doctrine of merger was applied by reference to the appellate authority's powers under section 251, including enhancement jurisdiction. The Tribunal held that merger depends on the full scope of matters the appellate authority could lawfully examine, not only the issues actually considered. Accordingly, once the assessment had merged in the appellate order, the Commissioner could not invoke section 263 to revise matters within that appellate jurisdiction. The revisional order was set aside and the assessee's appeal succeeded. Case-Laws Income Tax Tue, 25 May 1982 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=56271