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2018 (8) TMI 747 - AT - Income TaxRevision u/s 263 - Doctrine of merger - CIT observed that, AO has not made necessary enquiries/ verification with reference to the purchases - AO has rejected the books of assessee and disallowed 25% of such purchase in the assessment - Held that:- when the addition made by the AO was the subject matter of appeal before the ld. CIT(A) and this issue was pending before the ld. CIT(A) then, the Pr. CIT has not powered to invoke the jurisdiction of U/s 263 of the Act on the same issue. In view of the above facts and circumstances of the case the issue which was the subject matter of appeal before the ld. CIT(A) at the time of issuing the show cause notice then, the initiation of proceedings U/s 263 itself is not valid. - Decided in favor of assessee.
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