CIT's Section 264 Order Deemed Invalid; Appeal Restored to CIT(A) for Reconsideration Due to Jurisdiction Overreach.

Doctrine of Merger of an order - CIT(A) observed that the appeal has been merged with order of Revision passed by the CIT u/s 264 - Prohibition u/s 264(4) - the appeal of the assessee was pending before the Ld. CIT(A) during the relevant time when the matter was decided by the Ld. CIT u/s 264 - Therefore, the Ld. CIT under section 264 has exceeded his jurisdiction by passing the order which is not sustainable in the eyes of law. - Matter restored before CIT(A) - AT .....

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