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    <title>2025 (3) TMI 2132 - ITAT NAGPUR</title>
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    <description>Assessment annulment based on alleged non-issuance of a show-cause notice under CBDT Instruction No. 20/2015 was considered unsustainable where the assessment record showed repeated scrutiny notices and questionnaires, and the assessee had submitted extensive financial and supporting documentation. The record therefore contradicted the finding that no opportunity had been provided. As the merits of the additions and disallowances had not been argued, those matters required determination by the appellate authority and were restored for decision on merits.</description>
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