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so far I know if matter goes in appeal than matters referred in appeal cannot be revised u/s 264
mr gopal is right- beacuse the matter which has gone an appeal become merged and cannot be revised.
But as u as per section 263, if appeal made to CIT(A) on certain matter
than on some other matter CIT can revise the order of AO u/s 263
I m not very sure but it can be because of in sec 263 -concept of Partial merger is followed.
and in sec.264 concept of total merger is folowed.
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