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2003 (9) TMI 328 - ITAT JODHPURExtract: .......his ground before this Tribunal for the first time being a legal one, but the assessee has not chosen to raise this issue before us by way of additional ground of appeal or by taking the same in the C.O. As a result, we do not need to decide this issue. 14. As a result, the appeal of the Department as well as the C.O. of the assessee are dismissed.
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