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2022 (4) TMI 273

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....a, Sr. DR ORDER Per Dr. B. R. R. Kumar, Accountant Member: The present appeal has been filed by the Revenue against the order of ld. CIT(A), Dehradun dated 28.04.2017. 2. The first issue is with regard to not recording the satisfaction of concealment and/or filing of inaccurate particulars of income. It is observed from the assessment order that after discussing the claim made by the assessee ....

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....urate particulars of income". 3. On this issue, we are guided by the following judgments: 1) Karnataka High Court: CIT vs. Manjunatha Cotton and Ginning Factory: 359 ITR 565 held that notice under section 274 should specifically state the grounds mentioned in section 271(1)(c) of the Act, i.e., whether it is for concealment of income or for furnishing of incorrect particulars of income. Sending....