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    <title>2025 (6) TMI 565 - ITAT GUWAHATI</title>
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    <description>The Tribunal held that the dispute required fresh adjudication by the first appellate authority because the assessee&#039;s explanations, additional submissions, and supporting evidence had not been properly considered. It found that both sides had to be given a fair opportunity of hearing, including compliance with Rule 46A before admission and consideration of additional material. The merits of the additions were not decided by the Tribunal. The matter was therefore set aside and restored to the first appellate authority for a fresh decision after giving reasonable opportunity to both the assessee and the Revenue.</description>
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      <description>The Tribunal held that the dispute required fresh adjudication by the first appellate authority because the assessee&#039;s explanations, additional submissions, and supporting evidence had not been properly considered. It found that both sides had to be given a fair opportunity of hearing, including compliance with Rule 46A before admission and consideration of additional material. The merits of the additions were not decided by the Tribunal. The matter was therefore set aside and restored to the first appellate authority for a fresh decision after giving reasonable opportunity to both the assessee and the Revenue.</description>
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