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2003 (7) TMI 720 - ALLAHABAD HIGH COURTExtract: .......Commissioner shall extend and shall be deemed always to have extended to such matters as had not been considered and decided in an appeal. 3. Similar view has been reiterated in CIT v. Jaykumar B. Patil 1999 236 ITR 469 (SC). Thus, in view of the above, we answer the reference in the negative, i.e. in favour of the Revenue and against the assessee.
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