Doctrine of Merger: Section 14A Disallowance Can't Be Revised by Principal Commissioner if Already Decided by CIT(A).

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....Revision u/s 263 - Doctrine of merger - the subject-matter in question “Disallowance under section 14A r.w.r.8D” ‘ has been considered and decided by the Commissioner of Income Tax (Appeals) - if any order of the assessing officer had merged in the order passed in appeal by the Commissioner of Income Tax (Appeals), the same cannot be set aside under section 263, in revision, by the Principal Commissioner of Income Tax. - AT....