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2005 (9) TMI 288 - ITAT RAJKOTExtract: .......ing of assessment after expiry of 4 years as per the first proviso to s. 147. We are, therefore, inclined to reverse the findings of lower authorities on this legal issue. As the legal issue has already been decided in favour of the assessee, we are allowing the appeal in favour of the assessee. In the result, the appeal of the assessee is allowed.
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