#Merger Doctrine

Once a scrutiny assessment is completed under Section 143(3), any prior intimation under Section 143(1) is absorbed and ceases to exist as an independent order. This means the Assessing Officer cannot later rely on the 143(1) intimation to justify a rectification under Section 154, ensuring finality in the assessment process and protecting taxpayers from retroactive adjustments based on preliminary notices.

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.

Once surplus land orders attain finality through statutory appeals, revisions, or writ proceedings, civil courts lose jurisdiction to entertain challenges. The Punjab & Haryana High Court reinforces that statutory finality under land ceiling laws overrides civil claims, even where limitation periods or administrative actions are invoked to reopen settled orders.

Delhi High Court holds that unexplained delay of four years bars challenge to CAT order; administrative representation does not revive time-barred writ petition.

ITAT Mumbai holds that an assessment order under Section 143(3) cannot retain adjustments from a quashed Section 143(1) intimation. Consequential relief mandated.