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1965 (12) TMI 19 - KERALA HIGH COURTWhether all or any of the conditions mentioned in rule 48 of the IT Rules 1922 have been satisfied - It is necessary to conduct an investigation to find out whether a discretion is vested in the ITO or not by determining whether any part of the rule [rule 48(1)], had been satisfied and if it is possible to decide whether there was an error or not only after coming to the conclusion whether r. 48(1) has been satisfied, it appears to me the error is not an error apparent on the face of the record
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