Doctrine of Merger in Income Tax Assessment: An Analysis of ITAT Chennai's Recent Judgment

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....inciples. One such principle that has gained significance over the years is the "Doctrine of Merger." This doctrine becomes particularly relevant when appeals or revisions are filed against assessment orders. In a recent judgment by the Income Tax Appellate Tribunal (ITAT) Chennai, the doctrine of merger took center stage, and its implications are worth examining. The Case: The case in....

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....assessment was eventually framed under Section 153C, making specific disallowances. * Doctrine of Merger: The taxpayer contended that since the larger issues, including legal issues, were already pending before the Commissioner of Income Tax (Appeals) (CIT(A)) in the appeal against the order passed under Section 153C r.w.s 144, the doctrine of merger applied. According to this doctrine, when a....