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    <title>2026 (6) TMI 225 - ITAT AHMEDABAD</title>
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    <description>The Commissioner (Appeals) may issue directions arising from appellate proceedings under section 251(1)(a), read with section 150(1), but the direction must remain within lawful limits. A direction may authorise the Assessing Officer to consider reopening a preceding assessment year and examine taxability of unexplained investment in accordance with law. It cannot, however, compel an addition in that year as if the tax outcome were already determined. The original direction was therefore not sustained in full and was modified to confine the Assessing Officer to lawful reopening and consideration, leaving the assessee free to contest the matter.</description>
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