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The appeals by the assessee were consolidated and disposed of by a common order by ITAT DELHI-C. The appeal for the assessment year 1971-72 was taken first. The AAC's order was set aside for not considering the jurisdiction issue raised by the assessee. The second appeal involved the assessment of income from SOP, which was accepted at Rs. 1800 based on past practice. ITA No. 3137/(DEL)/81 was allowed, and ITA NO. 3136 (DEL)/81 was partly allowed for statistical purposes.
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