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2013 (3) TMI 173 - HC - Income TaxRe opening of assessment - appeal filed by the assessee u/s 260A assailing order of the ITAT dismissing appeal regarding reassessment - As per ITAT income declared by the company regarding business expenditure were dis-allowable u/s 40A(3) and the reasoning forthcoming from the assessee as regards expenses incurred for expenditure regarding training of staff was not acceptable - Held that:- Merely question of law is not sufficient and the requirement of statute as that there should be a substantial question of law which requires consideration u/s 260A of the Act and rightly so the legislature is certainly of the view that as regards the factual matrix the matter being examined at various levels upto the ITAT such factual matrix must be put to rest at some stage and that being so only substantial question of law if emerges certainly is to be considered by this Court. On submission made by appellant no substantial question of law at all emerges to be considered by this Court in the instant income tax appeal - against assessee.
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