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    <description>A tax appeal rejected solely for an 87-day filing delay was set aside because the Tribunal had not examined the merits, and the assessee had offered an explanation for the delay. The Court also relied on parity with a later assessment year, where similar issues had already been remitted for fresh consideration. To secure an opportunity of hearing and ensure substantial justice, the matter was restored to the Assessing Officer for de novo adjudication on merits.</description>
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