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    <description>TDS on payments to a non-resident was not finally determined because the assessee had not placed adequate submissions before the Assessing Officer and later relied on additional factual and legal material, including recent authorities, before the appellate forum. The issue was therefore considered suitable for reconsideration at the assessment stage rather than adjudication on merits. The matter was restored to the Assessing Officer for de novo adjudication, with directions to afford the assessee due opportunity of hearing.</description>
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      <description>TDS on payments to a non-resident was not finally determined because the assessee had not placed adequate submissions before the Assessing Officer and later relied on additional factual and legal material, including recent authorities, before the appellate forum. The issue was therefore considered suitable for reconsideration at the assessment stage rather than adjudication on merits. The matter was restored to the Assessing Officer for de novo adjudication, with directions to afford the assessee due opportunity of hearing.</description>
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