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2018 (4) TMI 120 - AT - Income TaxAssessment u/s 153C - Period of limitation - assessment barred by limitation - issue of limitation raised by the assessee before the Tribunal for the first time - Held that:- The additional grounds raised by the assessee being legal in nature going to the root of the matter, therefore, deserve to be admitted on record. We, however, find that there is nothing on record from the side of assessee as to how the impugned assessment order is being termed as barred by limitation. It is, however, an undisputed fact that this issue was never raised by the assessee before the authorities below and therefore, there is no decision of the lower authorities on this aspect of the case. In presence of these facts, we deem it expedient in the interest of justice that the matter should go back to the file of the ld. CIT(A) for deciding the appeal of the assessee on legal aspect as well as on merits of additions afresh. - Decided in favour of assessee for statistical purposes.
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