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2022 (10) TMI 458 - AT - Income TaxReopening of assessment u/s 147 - claim of deduction u/s 10B - reopening of the assessment after a period of 4 years from the end of the relevant A.Y - CIT-A sustaining the reassessment order of AO who had reopened the assessment undersection 148 - HELD THAT:- We find the order of the CIT (A) is a very skechy and a cryptic one. The order of the learned CIT (A) neither addresses the grounds raised by the assessee challenging the validity of the re-assessment proceedings nor addresses the allowability of claim of deduction under section 10B on account of such false and inaccurate particulars. On a pointed query raised by the Bench, the learned Counsel for the assessee submitted that he has no control over the reasons given by CIT (A) while allowing the deduction especially when the assessee has filed all requisite details before the AO as well as before the CIT (A). We find neither the learned CIT (A) has addressed the various issues raised by the assessee challenging the validity of the re-assessment proceedings nor the CIT (A) has addressed the issues raised by the Assessing Officer while denying the claim of deduction u/s 10B. Considering all we deem it proper to restore the issue to the file of the learned CIT (A) with a direction to adjudicate the issue of validity of re-assessment proceedings as well as the claim of deduction u/s 10B of the I.T. Act by passing a speaking order giving pointwise reasonings on both the issues. The grounds raised by the Revenue as well as the grounds raised by the ass in the cross objection are accordingly allowed for statistical purposes.
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