Petitioner's challenge dismissed due to doctrine of merger; failed to contest show cause notice and Order-in-Original timely.

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....The doctrine of merger has come into play and the show cause notice is not available any more for the petitioner to challenge - It is not the case of the petitioner that they challenged either the impugned show cause notice or the Order-in-Original at the relevant point of time on the ground that the show cause notice was issued by a person not assigned the role of a proper officer. - HC....