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    <description>Additional jurisdictional grounds challenging the validity of the assessment on transfer of jurisdiction, change of assessing officer, and the alleged inapplicability of section 147 to material found in the search of another person were admitted because they went to the root of the assessment. As resolution depended on records and factual verification, including whether jurisdiction had been validly transferred and whether a written order was required, the matter involved a mixed question of fact and law. The Tribunal therefore considered it appropriate for the first appellate authority to examine the grounds first and remitted them for adjudication in accordance with law.</description>
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