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Merger Doctrine: CIT Cannot Reassess Deduction Eligibility u/s 263 if AO Order Merged with CIT(A) Order.
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Jurisdiction u/s 263 – Doctrine of merger - once the order of the AO got merged with the appellate order of the CIT(A) on a particular issue, the CIT cannot invoke the provisions of section 263 on the premise to verify the eligibility of deduction under section 80-IB - AT