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    <title>2024 (8) TMI 1495 - ITAT KOLKATA</title>
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    <description>Assessment under section 147 read with section 144 was based on an accrual addition treating a joint development agreement as a transfer under section 2(47), but the assessee contended that the project had not materialised and possession had not been handed over. As proper opportunity of representation had not been afforded, the matter was considered fit for restoration to ensure a fair hearing. The assessment order was set aside and the case was remanded to the Assessing Officer for de novo assessment after giving the assessee proper opportunity.</description>
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      <description>Assessment under section 147 read with section 144 was based on an accrual addition treating a joint development agreement as a transfer under section 2(47), but the assessee contended that the project had not materialised and possession had not been handed over. As proper opportunity of representation had not been afforded, the matter was considered fit for restoration to ensure a fair hearing. The assessment order was set aside and the case was remanded to the Assessing Officer for de novo assessment after giving the assessee proper opportunity.</description>
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