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2020 (10) TMI 845 - HC - Income TaxReopening of assessment u/s 147 - assessment was reopened after a period of four years on the ground that income chargeable to tax has escaped assessment by reason of failure on the part of the assessee to disclose fully and truly all material facts necessary for completion of the assessment for the concerned - Tribunal held that on going through the orders passed by the AO and the CIT(A) and the materials, which was placed before the Tribunal, AO has reopened the assessment based on the materials, which were already available on record and it is a mere change of opinion - HELD THAT:- Revenue seeks to re-argue the factual position, which is impermissible in an appeal under Section 260A of the Act, where, we are required to decide only Substantial Questions of Law, which arises for consideration. The power conferred on this Court under Section 260 A of the Act is not to act as a third Appellate Court over the orders passed by the Tribunal. We find from the grounds raised before us that there is nothing brought on record by the Revenue to show that the order passed by the Tribunal was factually incorrect or for that matter, the order passed by the CIT(A). No substantial question of law.
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