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Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad
reopen the assessments and to make an addition. In the present case, decisions of Hon'ble Delhi, Gujarat and Bombay High Courts are in favour of the assessee. The decisions of Hon'ble Kerala High Court and Karnataka High Court are against the assessee. We find that after examining the facts and circumstances of the case, the judgement