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    <description>The Tribunal held that the second re-opening of the assessment was valid as procedural defects from the first re-opening were rectified, and there was no legal prohibition against a second re-opening. The matter was remanded to the CIT(A) for adjudication on the merits as the CIT(A) had annulled the assessment on legal grounds without addressing the merits. The appeal of the revenue was allowed for statistical purposes, and the case was restored to the CIT(A) for further consideration.</description>
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      <description>The Tribunal held that the second re-opening of the assessment was valid as procedural defects from the first re-opening were rectified, and there was no legal prohibition against a second re-opening. The matter was remanded to the CIT(A) for adjudication on the merits as the CIT(A) had annulled the assessment on legal grounds without addressing the merits. The appeal of the revenue was allowed for statistical purposes, and the case was restored to the CIT(A) for further consideration.</description>
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