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1991 (10) TMI 70 - ITAT AHMEDABAD-AExtract: .......s prescribed in the section he may seek to reopen it, cannot make an assessment in cases where the dividend has actually been declared and paid before the date of his order. 9. In the final analysis we quash the orders passed by the ITO under section 23A(1) of the Act for each of the assessment years under consideration. 10. The appeals are allowed
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