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2018 (12) TMI 1952 - HC - Income TaxReopening of assessment u/s 147 OR proceedings u/s 153C - HELD THAT:- As substantial questions of law arise for consideration: (i) Whether on the facts and in the circumstances of this case, the Income Tax Appellate Tribunal was justified in upholding the validity of the proceedings under section 147 of the Income Tax Act, 1961? (ii) Whether on the facts and in the circumstances of this case, the Income Tax Appellate Tribunal was justified in holding that the proceedings under section 147 were rightly taken instead of proceedings under section 153C of the Income Tax Act, 1961? (iii) Whether on the facts and in the circumstances of this case, the Income Tax Appellate Tribunal was justified in upholding the reopening for the assessment year 2012- 13? (iv) Whether on the facts and in the circumstances of this case, the Income Tax Appellate Tribunal was justified in upholding the addition of Rs.1,22,24,800/- in the assessment year 2012-13, despite the fact that the appellant was not a seller or even the confirming party in the sale deed?
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