Second deployment of Patch will fail with error "import: FAILURE: A patch cannot be imported as a holding solution".

The reason why the pipeline failed to import the second patch after the first one is due to the pipeline step of the system using StageAndUpdate, while the Power Platform pipeline defaulted to ‘Upgrade’ with Overwrite only.

Based on the article for Power Platform pipelines, "Not currently. Pipelines default import behavior is Upgrade with Overwrite customizations."

Normally, for patch, the default method should be ‘Update’ instead. And we cannot use ‘Upgrade’ for patch. However, because Power Platform pipeline only support ‘Upgrade’, it causes conflict in the import logic for patch deployment. This is currently by-design behavior

For the pipelines in Power Platform to fully function as a deployment channel, we need the Update to be included in the future to enhance user experience.