9911796707
TMI Blog2008 (2) TMI 54X X X X Extracts X X X X X X X X Extracts X X X X ..... court, vide order dated February 26, 2001, passed in I. T. C. No. 157 of 1996 filled by the Revenue, to draw up a statement of the case and refer the following substantial question of law to this court, the Income-tax Appellate Tribunal, Chandigarh Bench, Chandigarh (hereinafter referred to as the ITAT"), has referred the said question for the opinion of this court: "Whether, on the facts and in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e declared income on September 30, 1983. Subsequently, the case was reopened under section 148 of the Act on certain information when it was noticed that the assessee had understated the purchase price of 810 shares of M/s. Angoora Wool Combers Pvt. Ltd. 3. The Assessing Officer issued notice on May 10, 1985, to the assessee. Pursuant to the return filed by the assessee on February 19, 1986, the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bunal. The Income-tax Appellate Tribunal vide order dated June 5, 1990, deleted the entire addition while relying upon its earlier decision dated April 4, 1990, passed in I.T.A. No. 175 of 1986 in the case of Shri Dharam Pal and it was held that the issue involved regarding the price of the share was squarely covered by the said decision. In view of the said order, the assessee went in appeal agai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... are was deleted by the Income-tax Appellate Tribunal and that order has become final. 7. After hearing counsel for the Revenue and going through the reference as well as the finding recorded by the Income-tax Appellate Tribunal pertaining to the deletion of the addition made by the Assessing Officer as also the order deleting the penalty, we are of the opinion that once the entire addition has be ..... X X X X Extracts X X X X X X X X Extracts X X X X
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