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The Allahabad High Court was asked to opine on whether the CIT could assume jurisdiction under section 263 of the Income-tax Act, 1961. The court referenced the Doctrine of Merger and amendments to section 263(1), concluding that the Commissioner's powers extend to matters not considered in an appeal. The judgment favored the Revenue against the assessee. (Case citation: 2003 (7) TMI 720 - ALLAHABAD HIGH COURT)
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