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By way of this appeal, the appellant challenges correctness of the reasoning of the Tribunal for declining to consider pertinent issues that go into the root of the matter and relate to assumption of jurisdiction and validity of the reassessment proceedings undertaken by the revenue under s. 153C of the Act.

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Sec. 253(1) & 253(4) of Income-tax Act, 1961 – Appeal - The appeal is directed against the order of ITAT allowing Revenue’s appeal and further remanding the matter to the file of the AO for fresh adjudication. Tribunal inter alia rejected additional jurisdictional grounds of assessee under Rule 27 of ITAT Rules to assail the findings of CIT(A). Thus, the appellant challenges correctness of the reasoning of the Tribunal for declining to consider pertinent issues that go into the root of the matter and relate to assumption of jurisdiction and validity of the reassessment proceedings undertaken by the revenue under s. 153C of the Act. High Court allowed the appeal of the assessee by remanding back the matter to the Tribunal with a direction to hear the matter afresh by allowing the assessee to raise the additional grounds, under r. 27 of the Rules, pertaining to issues relating to the assumption of jurisdiction and the validity of the reassessment proceedings under s. 153C of the Act. - SANJAY SAWHNEY V/s PR. CIT - [2020] 316 CTR 392 (DEL)

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