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In the result, the appeal of the assessee for Assessment Year
Bench: Sri Rajpal Yadav(Kz) & Dr. Manish Borad
253 ITR 749, 172 CTR 339, 121 TAXMANN 43, (2002) 108 COMP. CAS. 675 (GUJ.)] and others “In the background of the aforesaid discussion and Judicial Pronouncements cited above, considering the averments of the AO, it is evident that the reasons stated by the Assessing Officer while Page 12 of 114 I.T.A. No.: 43/GTY/2022 I.T.A. No.: 2/GTY/2023 Assessment Year