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2023 (9) TMI 841 - HC - Income TaxReopening of assessment - under-declaration of the investment made - in Block assessment appeal was disposed of in favour of respondent/assessee on the ground that no incriminating material was found in the search and seizure action concerning the unexplained investment in the subject property - Whether merely because certain issues and additions were considered during the block assessment proceedings, which were deleted by the appellate authority on technical grounds, the same, could not form the basis for triggering reassessment proceedings? - HELD THAT:- Tribunal has, rightly, sustained the view of the CIT(A). A perusal of the proposed question of law would show that the appellant/revenue has instituted these appeals to agitate that aspect of the matter which relates to the validity of triggering reassessment proceedings, because some of the issues and additions involved were common to the block assessment proceedings as well as the reassessment proceedings. Thus, according to us, on merits, the impugned order needs no interference. The appeals are accordingly closed, with the caveat that the question of law raised by the appellant/revenue is left open.
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