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2021 (9) TMI 330 - ITAT DELHIReopening of assessment u/s 147 - reopening argued as time barred - assessee argued there cannot be two notices u/s 148 of the Act for the same transaction - addition made invoking of section 50C(1) - HELD THAT:- During the course of hearing, Ld. Sr. DR fairly conceded that these grounds have not been adjudicated by way of a speaking order. We, therefore, set aside the impugned order and restore the grounds of appeal raised by the assessee in this appeal before Ld.CIT(A) to decide the appeal afresh by way of speaking order on each ground raised in Form No.35 by the assessee The case being very old related to the Assessment Year 2006-07. However, in the absence of a specific adjudication by the First Appellate Authority, we deem it proper to restore the grounds to the file of Ld.CIT(A) for adjudicating the grounds raised in Form No.35. Ld.CIT(A) is hereby directed to dispose of grounds - Appeal of assessee allowed for statistical purposes.
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