TMI Blog2006 (2) TMI 154X X X X Extracts X X X X X X X X Extracts X X X X ..... ial questions of law for consideration in this appeal: "I. Whether, on the facts and in the circumstances of the case, the learned Income-tax Appellate Tribunal has erred in law in holding that the reassessment proceedings were bad in law and based on the change of opinion, ignoring the fact that the proceedings under section 147 were validly initiated on the material evidence available on recor ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ction of the assessee that the initiation of proceedings under section 148 was without jurisdiction and the proceedings were quashed. The said order was affirmed by the Tribunal by the order under appeal. When the matter came up for hearing on December 2, 2005, this court directed learned counsel for the Revenue to place on record the reasons that were recorded by the Assessing Officer before as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... unexplained investment may be estimated at Rs. 5 lakhs. Hence the total income escaped to investment is (5 + 1.69 lakhs) Rs. 6.69 lakhs. Since an income chargeable to tax to Rs. 6.69 lakhs, for the assessment year 1989-90 has escaped assessment within the meaning of Explanation 2(a) of section 147 of the Income-tax Act, 1961, in the case of the firm, M/s. Mahesh Gum and Oil Industries, Osiyan, t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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