2017 (8) TMI 1597

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..... e the bench at the time of hearing. Therefore, the ground with respect to reopening was not considered. However, in the interest of justice, since the assessee has come up with the prayer before us for considering the ground with respect to reopening U/s.147 of the Act, we are of the considered view that a fair opportunity is to be provided to the assessee. Therefore, we hereby recall the order of .....

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..... that the Tribunal had not decided the legal issue with respect to reopening of assessment U/s.147 of the Act. It was therefore pleaded that, to that extent the order of the Tribunal may be recalled in order to consider the ground with respect to reopening of assessment U/s.147 of the Act. The Ld.DR strongly objected to the submission of the Ld.AR. 3. We have heard the rival submissions and car .....

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