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    <title>2021 (5) TMI 945 - ITAT AHMEDABAD</title>
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    <description>Additional evidence showing registration under section 12AA was admitted under Rule 29 because it went to the root of the dispute over exemption under sections 11 and 12. As the certificate had not been before the first appellate authority, the merits of the exemption claim were not examined and the matter was restored for fresh adjudication after considering the registration evidence. The operative effect was procedural: the assessee obtained remand for de novo consideration, with the substantive exemption issue left open for decision by the CIT(A).</description>
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      <description>Additional evidence showing registration under section 12AA was admitted under Rule 29 because it went to the root of the dispute over exemption under sections 11 and 12. As the certificate had not been before the first appellate authority, the merits of the exemption claim were not examined and the matter was restored for fresh adjudication after considering the registration evidence. The operative effect was procedural: the assessee obtained remand for de novo consideration, with the substantive exemption issue left open for decision by the CIT(A).</description>
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