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1992 (11) TMI 133 - ITAT DELHI-BExtract: .......t relevant facts to decide whether the assessee rsquo s case does fall for consideration under s. 67(3) are not before us. This aspect of the matter is accordingly restored to the file of the AO to be considered de novo on merits, after giving reasonable opportunity to the assessee. 14. In the result, the Revenue rsquo s appeals are partly allowed.
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