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In the result, the assessee’s appeals are allowed for statistical purposes
Bench: Shri Sanjay Arora & Ms. Kavitha Rajagopal
161 / [2020] 429 ITR 284 (Kar)) as being supportive of the assessee’s case. 4.6 The Apex Court in ITO v. Seghu Buchiah Setty [1964] 52 ITR 538 (SC) held that there was not much difference between annulment and set aside of an order inasmuch as both wipe out the original order; in it’s words:(pg. 544) ‘There