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2022 (1) TMI 1357 - AT - Income TaxAssessment order u/s 144 r.w.s 147 treating assessee as AOP - HELD THAT:- We find that before the ld. CIT(A), the assessee filed copy of Satakhat. On perusal of the contents of said Satakhat, we find that it has direct relevance to the grounds of appeal raised by the assessee and the same require consideration. Therefore, instead of the fact that the copy of Satakhat was filed independently on not in the record of assessment for the year under consideration before AO or not, we admit the same as relevant evidence for real determination of issue in hand and remit the issue to the file of CIT(A) to adjudicate the issue afresh by considering the Satakhat dated 04.04.2011 and pass the order in accordance with law. In the result the ground No. III is allowed for statistical purpose. Addition is made on estimation of income/project - The issue relevant to estimation of income of AOP is interlinked and also remitted back to CIT(A) to adjudicate the same after adjudication of ground of appeal in A.Y. 2011-12. The assessee is given liberty to file evidence / additional evidence to substantiate the ground of appeal and move appropriate application in case fresh/new evidence is filed to substantiate its ground of appeal or its contention.
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