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    <title>2004 (8) TMI 367 - ITAT NAGPUR</title>
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    <description>The Tribunal annulled the assessments for all years in question, determining that they were completed under the influence of higher authorities, rendering them illegal. The Assessing Officer (AO) lacked independence, as the assessments were directed by the Deputy Director of Income-tax (Investigation) [DDIT (Inv.)], New Delhi. Consequently, the appeal by the Revenue was dismissed as infructuous. The Tribunal also found procedural unfairness, as the AO failed to provide the assessee with a reasonable opportunity to be heard and did not allow cross-examination of witnesses. The actions of the DDIT (Inv.) exceeded jurisdiction, further invalidating the assessments.</description>
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      <title>2004 (8) TMI 367 - ITAT NAGPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=70911</link>
      <description>The Tribunal annulled the assessments for all years in question, determining that they were completed under the influence of higher authorities, rendering them illegal. The Assessing Officer (AO) lacked independence, as the assessments were directed by the Deputy Director of Income-tax (Investigation) [DDIT (Inv.)], New Delhi. Consequently, the appeal by the Revenue was dismissed as infructuous. The Tribunal also found procedural unfairness, as the AO failed to provide the assessee with a reasonable opportunity to be heard and did not allow cross-examination of witnesses. The actions of the DDIT (Inv.) exceeded jurisdiction, further invalidating the assessments.</description>
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