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    <title>2015 (9) TMI 1631 - DELHI HIGH COURT</title>
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    <description>The Court ruled in favor of the Respondent Assessee, emphasizing procedural fairness and disallowing the Revenue from raising new issues not previously brought before the Assessing Officer. The judgment dismissed the claim for repayment of a loan as an application of income, highlighting the importance of addressing all relevant issues during the assessment process. The Court also rejected the Revenue&#039;s attempt to project a notional tax effect, emphasizing the requirement for a genuine tax impact. Consequently, the appeal was dismissed in favor of the Respondent Assessee based on the arguments and considerations presented during the proceedings.</description>
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      <description>The Court ruled in favor of the Respondent Assessee, emphasizing procedural fairness and disallowing the Revenue from raising new issues not previously brought before the Assessing Officer. The judgment dismissed the claim for repayment of a loan as an application of income, highlighting the importance of addressing all relevant issues during the assessment process. The Court also rejected the Revenue&#039;s attempt to project a notional tax effect, emphasizing the requirement for a genuine tax impact. Consequently, the appeal was dismissed in favor of the Respondent Assessee based on the arguments and considerations presented during the proceedings.</description>
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