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2019 (5) TMI 347 - HC - Income TaxSubstantial question of law - Addition u/s 36(1) - debts actually written off - excluding the income from the Bangkok branch from the total income India- Thailand DTAA - HELD THAT:- Both the issues have been remanded back to the Assessing Officer to consider both the issues afresh. Since it is only remand order, we are of the clear opinion that no substantial question of law can be actually said to be arising from the said order of learned Tribunal. The matter is open before the Assessing Officer, who of'course is expected to take a considered view in proper manner after giving due opportunity of hearing to the Assessee. Learned counsels were unable to inform as to whether any order has been passed or not by the Assessing Authority so far pursuant to the remand order passed by the learned Tribunal on 14th December 2007. Thus, we return the aforesaid questions of law unanswered, lest it affects the exercise of discretion by the Assessing Officer.
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