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Substantial question of law to be made u/s 260A - prerequisite of admission of the appeal before the High court - The ITAT hold that the assessee had correctly offered the net amount to tax and deleted the additions made by the AO - Further, the ITAT allowed the cross-objection of the assessee and hold that the reopening of the case of the assessee tantamounts to change of opinion which is not permissible as per Section 147 - The court found that the questions raised by the appellant did not constitute substantial questions of law, as they primarily pertained to disputed facts rather than points of law. Hence, the appeal was dismissed.
Substantial question of law to be made u/s 260A - prerequisite of admission of the appeal before the High court - The ITAT hold that the assessee had correctly offered the net amount to tax and deleted the additions made by the AO - Further, the ITAT allowed the cross-objection of the assessee and hold that the reopening of the case of the assessee tantamounts to change of opinion which is not permissible as per Section 147 - The court found that the questions raised by the appellant did not constitute substantial questions of law, as they primarily pertained to disputed facts rather than points of law. Hence, the appeal was dismissed.
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