#Doctrine of Merger

ITAT Ahmedabad rules that reassessment under Section 147 is invalid if initiated after the merger of the original assessment with the CIT(A) order, unless there is a failure to disclose material facts. The ruling reinforces procedural safeguards against arbitrary reassessment, impacting tax litigation strategy for government and corporate assessees.

Landowners who received compensation based on a Reference Court award may file a second application under Section 28-A to claim parity with a later High Court enhancement, even if the first application was already decided. The Supreme Court affirms that the beneficent intent of the law and the doctrine of merger override technical bar arguments, ensuring equitable treatment for similarly situated landowners.

Punjab and Haryana High Court holds that when appellate decree does not specify time for deposit, reasonable time applies; doctrine of merger overrides original time limits under Specific Relief Act.