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    <description>Non-compliance with pre-deposit under Section 35F did not justify sustaining dismissal where reconciliation material and a Chartered Accountant&#039;s certificate indicated that the tax liability had substantially been discharged and the merits had not been examined. Because the original and appellate authorities had not considered the substantive liability on the basis of the additional material, the dispute required de novo adjudication. The impugned orders were set aside and the matter was remanded to the original authority to reconsider the reconciliation statement and supporting certificate and to decide the controversy afresh after granting a reasonable opportunity of hearing.</description>
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      <link>https://www.taxtmi.com/caselaws?id=205305</link>
      <description>Non-compliance with pre-deposit under Section 35F did not justify sustaining dismissal where reconciliation material and a Chartered Accountant&#039;s certificate indicated that the tax liability had substantially been discharged and the merits had not been examined. Because the original and appellate authorities had not considered the substantive liability on the basis of the additional material, the dispute required de novo adjudication. The impugned orders were set aside and the matter was remanded to the original authority to reconsider the reconciliation statement and supporting certificate and to decide the controversy afresh after granting a reasonable opportunity of hearing.</description>
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