2012 (7) TMI 1124

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....Advocate Respondent by : Shri Shaji P. Jacob, Addl. CIT ORDER V. DURGA RAO, J. These appeals by the assessee are directed against the orders passed by the CIT(Appeals) dated 25-11-2010 for the assessment years 2006-07 and 2007-08 and dated 02-05-2011 for the assessment year 2008-09. As common issues are involved in all these appeals, they were heard together and are being disposed....

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.... 3. The learned DR, on the other hand, submitted that the ground No.3 raised by the assessee for the assessment years 2006- 07 and 2007-08 is for the first time before the Tribunal and therefore it should not be remitted back. In reply, the learned counsel for the assessee submitted that all the facts are available on record. Therefore, the entire issue can be remitted back to the AO for de....