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2019 (11) TMI 1757 - AT - Income TaxReopening of assessment u/s 147 - HELD THAT:- As it is an admitted fact that the assessee has raised the ground challenging the issuance of notice u/s 148 for reopening the assessment u/s 147 but the same was not before the Ld. CIT(A) and there was no discussion in the impugned order. As therefore, in the absence of clear facts on record regarding the reopening of the assessment under section 148 of the Act, deem it appropriate to set aside this case back to the file of the Ld. CIT(A) to be adjudicated afresh by considering the legal grounds raised by the assessee and providing due and reasonable opportunity of being heard to the assessee. Appeal of the Assessee is allowed for statistical purpose.
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