INCOME TAX ACT, 1961

Revision under section 263 - Validity -Doctrine of merger

Held: As per Explanation (c) in section 263, words considered and decided were conjoined with a conjunction and, that means matter should be considered by CIT (A) and was equally necessary that CIT (A) should decide it by giving his appropriate finding, therefore, both conditions had to be fulfilled to apply doctrine of merger.

Income-tax Act, 1961, Section 263

A.Y. : Block period 1st April, 1996 to 24th Oct., 2002
Decision: In favour of revenue.

Ranka Jewellers v. Addl. CIT