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The matter needed to go back to the file of the AO for framing denovo assessment on merits of the issue as well on legal/jurisdictional ground raised by assesse wrt reopening of the concluded assessment u/s 147 of the 1961 Act.

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Sec. 147 of Income Tax Act, 1961— Re-assessment —SRI N. BALAKRISHNAN vs. ASSTT. CIT.[2020] 25 ITCD Online 008 (ITAT-CHENNAI)