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    <description>The appeals were allowed for statistical purposes. The Tribunal remitted the additional ground challenging the validity of the penalty notice to the Commissioner of Income Tax Appeals for review, emphasizing the importance of addressing all issues in an appeal at once. The Commissioner was directed to consider the additional ground and provide the assessee with an opportunity to be heard, following which further grounds could be raised if necessary. The order was pronounced on 2nd May 2018, concluding the proceedings.</description>
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      <description>The appeals were allowed for statistical purposes. The Tribunal remitted the additional ground challenging the validity of the penalty notice to the Commissioner of Income Tax Appeals for review, emphasizing the importance of addressing all issues in an appeal at once. The Commissioner was directed to consider the additional ground and provide the assessee with an opportunity to be heard, following which further grounds could be raised if necessary. The order was pronounced on 2nd May 2018, concluding the proceedings.</description>
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