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    <title>2025 (12) TMI 190 - ITAT AHMEDABAD</title>
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    <description>ITAT Ahmedabad held that the assessee&#039;s objection to the AO&#039;s jurisdiction under s.124(3) was not maintainable as it was raised for the first time before the Tribunal and not before the AO or CIT(A). Section 124 was treated as a self-contained code, and the additional ground on jurisdiction was dismissed. However, the Tribunal found violation of principles of natural justice as CIT(A) relied on the AO&#039;s remand report without granting the assessee an opportunity to rebut it. The addition towards alleged long-term capital gains was therefore set aside and the matter remanded to the jurisdictional AO for fresh adjudication after providing due opportunity of hearing.</description>
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      <title>2025 (12) TMI 190 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=782650</link>
      <description>ITAT Ahmedabad held that the assessee&#039;s objection to the AO&#039;s jurisdiction under s.124(3) was not maintainable as it was raised for the first time before the Tribunal and not before the AO or CIT(A). Section 124 was treated as a self-contained code, and the additional ground on jurisdiction was dismissed. However, the Tribunal found violation of principles of natural justice as CIT(A) relied on the AO&#039;s remand report without granting the assessee an opportunity to rebut it. The addition towards alleged long-term capital gains was therefore set aside and the matter remanded to the jurisdictional AO for fresh adjudication after providing due opportunity of hearing.</description>
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      <pubDate>Tue, 25 Nov 2025 00:00:00 +0530</pubDate>
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