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Bench: BEFORE: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)
167 ITR 471 (SC)]*, which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals. 3. We shall take appeal of the assessee in ITA No. 463/Chd/2023 for A.Y 2018-19 as a lead case for discussion wherein assessee has raised the following effective grounds: 1. That having regard to the facts