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1981 (12) TMI 46 - ITAT BOMBAY-AExtract: .......ken by the CIT (Appeals), though for different reasons, and as such, we uphold his order on the basis of our reasons stated above. Since we have held that the reopening is not valid, and is such, we do not deem it proper to go into merits of the case. Accordingly, we confirm the order of the CIT (Appeals). 7. In the result, the appeal is dismissed.
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