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2018 (2) TMI 1929 - CALCUTTA HIGH COURTReopening of assessment u/s 147 - HELD THAT:- Revenue sought to argue that the factual basis of the Section 147 proceeding out of which this appeal arises is different from that in which Tribunal decided in favour of a partner of the assessee firm. But that is not what the Tribunal has held. In fact, the Tribunal has held otherwise. Moreover, the Revenue has not pleaded in the stay petition that the Tribunal went wrong on that count. None of the suggested questions also indicate that the factual basis of the case against an assessee's partner was factually different. Both the statutory appellate foram have gone against the Revenue on the question of reopening of assessment and we do not find any substantial question of law is involved in this appeal. The appeal is, accordingly, dismissed. The stay petition would also stand consequentially dismissed.
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