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of <h1>ITAT Chennai Ruling Emphasizes Doctrine of Merger, Protects Taxpayer Rights in Section 153C and 263 Assessment Case.</h1> The recent judgment by the Income Tax Appellate Tribunal (ITAT) Chennai focused on the doctrine of merger in income tax assessments. The case involved a taxpayer challenging an assessment framed under Section 153C r.w.s 144, arguing that the doctrine of merger applied because the issues were already pending before the Commissioner of Income Tax (Appeals). The doctrine limits the revisory jurisdiction of tax authorities when an appeal is pending. Citing judicial precedents, ITAT Chennai ruled in favor of the taxpayer, quashing the revision under Section 263 as invalid, thereby highlighting the doctrine's significance in safeguarding taxpayer rights.
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