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The issue relating to invoking of section 40(a)(ia) was not before the AO at all and in this background,...

The issue relating to invoking of section 40(a)(ia) was not before the AO at all and in this background, it was imperative for the CIT(A) to have issued an appropriate notice to the assessee - provisions of section 251(2) clearly militate against the aforesaid approach of the CIT(A) - AT .....

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