No applicability of Doctrine of Merger as Income retained by CPC was same as from Intimation u/s 143(1)(a)

MSTC Ltd. Vs Jurisdictional Assessing Officer (ITAT Kolkata)

Conclusion: Doctrine of merger did not apply because AO had accepted the returned income, thereby implying that no addition was made on account of the reasons for which the case was selected under scrutiny but the adjustment made to the income vide intimation issued by the CPC had been retained.

Held: Assessee had been mainly providing e-platform for conducting e-auction, e-procurement services for disposal of scrap arisings, surplus stores, etc. from PSUs and Government Department

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