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2021 (4) TMI 329

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..... e giving various opportunities from 13.11.2018 to 30.01.2019, there was no response from assessee s side and by clubbing the appeals for other assessment years, the ld. CIT(A) dismissed all the appeals after considering the written submissions of the assessee. Since the ld. Counsel for the assessee made a submission that the assessee was not provided sufficient opportunity of being heard and not a .....

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..... grounds, the assessee mainly challenged the exparte order passed by the ld. CIT(A) without affording sufficient opportunity of being heard and without addressing the grounds of appeal on merits. 2. Brief facts of the case are that the assessee has filed its return of income 31.10.2007 for the assessment year 2007-08 admitting total income of 2,46,94,134/- after claiming deduction under section .....

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..... tion 115JB of the Act, the Assessing Officer issued notice under section 148 of the Act. In response to the notice, the assessee filed a return of income on 04.03.2010 admitting revised book profit of ₹ 127,17,75,519/- adding the provision for doubtful debts of ₹ 3,74,75,663/-. Further, the assessed filed a letter dated 22.03.2010 requesting to furnish reasons for reopening the assessm .....

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..... und No. 1.4, the ld. Counsel for the assessee has submitted that the ld. CIT(A) has not provided sufficient opportunity of being heard and without addressing the grounds of appeal on merits, which is against the principles of natural justice and prayed for suitable directions by giving an opportunity of being heard to the assessee. Per contra, the ld. DR strongly supported the order passed by the .....

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..... t addressed the grounds of appeal on merits, we remit the matter back to the file of the ld. CIT(A) to adjudicate the issues on merits in accordance with law by affording an opportunity of being heard to the assessee. 7. In the result, the appeal filed by the assessee is allowed for statistical purposes. Order pronounced on the 19th February, 2021 in Chennai. - - TaxTMI - TMITax - Incom .....

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