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2020 (8) TMI 662

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..... aised before the AO and fairly conceded that if this Tribunal remand the matter to the file of AO the assessee will take the same contentions before this Tribunal. Taking into consideration the facts and circumstances of the case and submissions of ld. AR and ld. DR, we deem it proper to remand the issue to the file of AO for its fresh consideration. The assessee is liberty to file evidences if .....

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..... ilable on record. We note that new incumbent, the AO found that there was mistake on account of allowance of deduction u/s. 36(1)(viia) of the Act. Accordingly, a notice u/s. 154 of the Act issue and in response, the assessee filed a letter dated 21-10-2013. According to AO the ld. AR representing the assessee consented to the rectification in principle and accordingly the disallowances made to an .....

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..... of AO the assessee will take the same contentions before this Tribunal. 4. The ld. DR reported no objection in remanding the matter to the file of AO for its fresh consideration. 5. Taking into consideration the facts and circumstances of the case and submissions of ld. AR and ld. DR, we deem it proper to remand the issue to the file of AO for its fresh consideration. The assessee is libert .....

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