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2012 (12) TMI 754 - AT - Income TaxSetting Aside of Assessment u/s 263 – Held that:- Appeals filed by the assessee for both the years were on substantially different issues, vis-à-vis the issues for which proceedings under Section 263 were initiated and completed by the Commissioner of Income Tax, therefore CIT(Appeals) was obliged under law to deal with the grounds taken by assessee for the respective Assessment Years, since orders under Section.263 did not cover these aspects. Set aside the orders of the CIT(Appeals) for both the Assessment Years and remit the matter back to him for re consideration - appeals of the assessee for both the years allowed for statistical purposes.
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