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2016 (6) TMI 113 - HC - Income TaxReopening of assessment - 90% of the mining franchise fee in computing the tax liability of the assessee - Commissioner of Income Tax (Appeals) has categorically held that the deduction under Section 80HHC of the Act was the subject matter of scrutiny in assessment proceedings under Section 143(3) of the Act; re-computation of the same deduction, on the basis of existing information, is only a change of opinion also affirmed by ITAT - Held that:- As the jurisdiction, which this Court can exercise under Section 260-A of the Act, is only if a substantial question of law arises for consideration, and as the findings recorded by the Commissioner of Income Tax (Appeals) and the Tribunal, on the inapplicability of the proviso to Section 147 of the Act to the case on hand, are findings of fact, we are satisfied that no question of law, much less a substantial question of law, arises for consideration necessitating the present appeal being entertained under Section 260-A of the Act. - Decided against revenue
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