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2019 (5) TMI 778

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..... upholding the action of the AO. It is a settled law that even an administrative order has to be speaking one. In this regard, we draw support from M/S SAHARA INDIA (FIRM) , LUCKNOW VERSUS CIT, CENTRAL-I ANR [ 2008 (4) TMI 4 - SUPREME COURT] wherein it has held that even an administrative order has to be consistent with the rules of natural justice . We remit back the issues in dispute to .....

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..... Appeals)-13, New Delhi dated 20.3.2015 pertaining to assessment year 2007-08 to 2008-09. Since the issues involved in these appeals are common and identical, hence, the appeals were heard together and are being consolidated by this common order for the sake of convenience, by first dealing with Assessee s Appeal No. 4095/Del/2015 (AY 2007-08) and the result thereof will apply mutatis mutandis to o .....

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..... on the facts and circumstances of the case, the order of the Ld. CIT(A), Appeals-13, New Delhi is erroneous, both in law and on the facts. 4. That the appellant craves leave to add, alter, modify withdraw, amend, substitute any ground(s) of appeal either before or at the time of hearing. 2. Facts narrated by the revenue authorities are not disputed by both the partie .....

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..... sted that the issues in dispute may be set aside to the file of the Ld. CIT(A) with the directions to decide the same afresh, after giving adequate opportunity of being heard and pass a speaking order. 4. On the other hand, Ld. DR relied upon the orders of the authorities below. 5. After hearing both the parties and perusing the impugned order, we find considerable co .....

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..... issues involved in the Appeal and decide the same afresh by passing a speaking order, after considering all the evidences/documents. Needless to add that the assessee should be given adequate opportunity of being heard. However, the Assessee is directed through his counsel to appear before the Ld. CIT(A) on 10.07.2019 at 10.00 AM for hearing and to file all the evidences/documents e .....

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