ITAT Rules Doctrine of Merger not applicable to Income Retained by CPC from Intimation u/s 143(1)(a) of Income Tax Act

The Income Tax Appellate Tribunal (ITAT) has ruled that the doctrine of merger does not apply to income retained by the Centralized Processing Centre (CPC) from intimation under Section 143(1)(a) of the Income Tax Act. This decision came in a case where the assessee challenged the retention of income by the CPC, arguing that the doctrine of merger should apply, and the income should be considered as assessed. The ITAT held that the doctrine of merger, which implies that a lower authority’s decision merges into the higher authority’s decision, does not apply in this context. The tribunal clarified that the CPC’s intimation under Section 143(1)(a) is not an assessment order but a preliminary check of the return filed. Therefore, the income retained by the CPC cannot be considered as assessed income, and the doctrine of merger does not apply. This ruling provides clarity on the scope and application of the doctrine of merger in income tax proceedings.