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What is the difference between partial merger and total merger in DT Appeals and Revision Chapter

What is the difference between partial merger and total merger in DT Appeals and Revision Chapter


There are two concept in appeal, one is concept of total merger and second is concept of partial merger. For an assessee concept of total merger is applicable and for revenue the concept of partial merger is applicable. If assessee make an appeal on few matters of an order passed by AO to appellate authority, then it shall be deemed that whole order of AO has been merged with order of appellate authority for an assessee. For example Assessing office passed an order including 5 points and assessing make an appeal only against 3 point out of total 5 points then assessee can not make the appeal against reaming 2 point u/s 264 at latter time period because concept of total merger is affirmed for assessee and revenue can consider the remaining two points u/s 263 (if applicable) because of concept of partial merger is affirmed for revenue.

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