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In the result, the appeal of the assessee is allowed
Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Ashutosh Chandrakant Patel, The Assistant “Ashutosh” Commissioner Of Income Vs Near Power House, Zanda Chowk, Tax, Vapi Circle, Vapi. Silvassa, U.T. Of D. & N.H, Pan : Agmpp 3734 C Assessee / Appellant Revenue /Respondent
deduction U/s.80IB made by the learned assessing officer in the assessment order framed U/s.143(3) r.w.s 147 of the Act on the basis of some other grounds, which does not form part of the reasons recorded for re-opening the assessment.” 3.At the outset, Learned Counsel submits that assessee has raised additional grounds of appeal challenging the validity of reassessment