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2004 (7) TMI 288 - ITAT BOMBAY-WTExtract: ....... initiated, therefore, in view of the foregoing discussions and the opinion expressed hereby hold that Explanation 3 to section 18(1)(c) was wrongly invoked because this is not the case of a new assessee. Order of Ld. CWT(A) is reversed and the ground raised in these appeals is allowed. 6. In the result, all the appeals of the assessee are allowed.
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