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In the result, the stay application filed by the assessee is dismissed
Bench: Shri Kul Bharatshri Manish Borad
9. However, in para 5, the AO assessed income of the assessee at Rs.NIL. Therefore, it is not the case that the issue related to section 2(15) of the Act, was not under consideration before the Assessing Authority. In our considered view, any issue which was considered by the AO in the assessment order, such order would be open