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That the impugned assessment order dated 15.12.2017 passed by the Ld. Assessing Officer, Ludhiana and impugned order, dated 10.12.2018, passed by the ld. CIT (Appeals)-I, Ludhiana is liable to be set aside in view of the most material facts that the ld. AO has erred in passing the impugned assessment order without giving any opportunity of hearing as admittedly no notice u/s 148 was ever served by the ld AO

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Section 251 of the Income Tax Act, 1961—Commissioner (A)—Matter was to be remanded back to Commissioner (A) with a direction to assessee to address relevant facts on basis of which relief, if any, maintainable in law, could be granted to him as AO made addition to assessee's income on basis of estimation of gross profit rate. however, right to appeal was not properly exercised as assessee failed to comprehend nature of assessment order — Jiwan Lal vs. Income Tax Officer [2019] 179 ITD 475 (Chandigarh-trib)

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