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    <description>Material first produced before the first appellate authority could be acted upon only after compliance with Rule 46A, including recorded reasons for admission and an opportunity for the Assessing Officer to examine and rebut it. A remand report under section 250(4) was not a substitute for that mandatory procedure. As the evidence had not been tested by the Assessing Officer and the dispute affected the appellate decision at its core, the matter was restored for de novo adjudication after giving both sides due opportunity.</description>
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