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    <title>2025 (2) TMI 1972 - ITAT DELHI</title>
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    <description>The appellate order was found unsustainable because the request for transfer of the appeal under Notification No. 113/2022 dated 13.10.2022 was not duly considered, and the appeal was decided on the incorrect premise that the assessment followed DRP directions despite no DRP objections having been filed. This was treated as a breach of natural justice and a failure to adjudicate the appeal in accordance with law. The matter was therefore restored to the first appellate authority for fresh decision on merits.</description>
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      <description>The appellate order was found unsustainable because the request for transfer of the appeal under Notification No. 113/2022 dated 13.10.2022 was not duly considered, and the appeal was decided on the incorrect premise that the assessment followed DRP directions despite no DRP objections having been filed. This was treated as a breach of natural justice and a failure to adjudicate the appeal in accordance with law. The matter was therefore restored to the first appellate authority for fresh decision on merits.</description>
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