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1992 (6) TMI 85 - AT - Income TaxExtract: .......ection 41(1) is remitted to the ITO, we are of the opinion that this issue may also be remitted to the ITO for fresh consideration after giving adequate opportunity to the assessee of being heard. For this purpose we set aside the orders of the authorities below and remit the matter to the ITO. Both the appeals are allowed for statistical purposes.
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