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2022 (3) TMI 480 - HC - Income TaxReopening of assessment u/s 147 - amount received under Agricultural Debt Relief and Debt Waiver Scheme is taxable or not? - ITAT opined that the AO has correctly recorded the reasons and reopened the assessment and completed the assessment u/s. 147 of the Act thus, the reopening is valid and for amout received under scheme direct the AO to re-examine the issue afresh in accordance with law - HELD THAT:- Though the appellant challenged the aforesaid order of the Tribunal in respect of both the issues, by raising various grounds and also placing reliance on case laws, we are of the view that the Income-tax Act is a self-contained Act and this court under section 260A of the Act in its appellate jurisdiction, is not the proper forum for deciding such mixed questions. Therefore, we remand the matter to the Assessing Officer as done by the Tribunal, however, with a direction to consider all the issues raised by the appellant, without being influenced by any of the observations made by the Tribunal, and pass orders afresh, after providing reasonable opportunity to the appellant. Such an exercise shall be completed within a period of three months from the date of receipt of a copy of this judgment.
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