In the result, the appeal filed by the assessee is allowed, both on legal issue\nas well as on facts
144B of the Act. As such, I am of the\nview that the appellant should be given full opportunity to represent its case, to produce all the\nnecessary evidence which the appellant wishes to rely upon and after considering the entire\nsubmissions of the appellant, the Ld.AO should pass the fresh assessment order. Considering the\nfacts and circumstances