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2021 (9) TMI 508 - AT - Income TaxEx parte proceedings by CIT-A - denial of natural justice - Reopening of assessment u/s 147 - disallowance of depreciation, addition on account of share application under section 68 and disallowance of purchase - assessee has challenged the order of Ld. CIT(A) on the ground that order was passed without granting opportunity of hearing - HELD THAT:- CIT(A) has not recorded as to when the last date of hearing was fixed. The Ld. CIT(A) has not discussed the facts of the case, issues for determination and decision thereon. CIT(A) has not discussed the facts of the case on adjudication point of determination and the decision thereon for such decision, meaning thereby the order passed by Ld. CIT(A) is not as per the mandate of section 250(6) - Therefore instead of going on the merit of additional grounds of appeals and on the original grounds of appeals, we restore the matter back to the Ld. CIT(A) to adjudicate all the issues afresh in accordance with law. The assessee is given liberty to raise all legal or factual issues before the Ld. CIT(A). CIT(A) is directed to provide reasonable and fair opportunity of hearing to the assessee before passing the order afresh - Appeal of assessee is allowed for statistical purposes
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