Aalidhara Textool Engineers Pvt. Ltd, Surat vs. PCIT-1, Surat
In the result, the appeal of the assessee is allowed
ITA 94/SRT/2020[2014-15]Status: DisposedITAT Surat28 May 2021AY 2014-15
Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.94/Srt/2020 ("नधा"रणवष" / Assessment Years: (2014-15) (Virtual Court Hearing) Alidhara Textool Engineers Pvt. Ltd., Vs. The Pcit-1, Surat. Plot No.168, Udhyog Nagar Road, Udhna, Surat -394210. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaacd8469M (Assessee) (Respondent)
For Appellant: Shri Mehul Shah, CAFor Respondent: Shri Ritesh Mishra, CIT(DR)
Section 10Section 10(38)Section 115JSection 143(3)Section 14ASection 263
…the doctrine of merger will apply. The logic underlying the doctrine of merger is that there cannot be more than one decree or operative order governing the same subject-matter at a given point of time. In the case of CIT vs. Narpat Singh Malkhan Singh (1981) 128 ITR 77 (MP), the Hon’ble Madhya Pradesh High Court has very illustratively considered the doctrine of merger. In this case, the Income Tax Officer (ITO) had completed the assessment u/s 143(3) of the Act against which the assessee preferred an appeal before the AAC confining his objections to certain disallowances of expenses by the ITO. The AAC partly a…