2012 (8) TMI 951

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.... view that, for Assessment Year 1996-1997, on the question of re-opening, the High Court has not considered the issue arising in this case. It is correct that Income Tax Appellate Tribunal [`ITAT', for short] has decided the matter in favour of the assessee. However, an important aspect has not been considered in appeal by the High Court under Section 260A of the Income Tax Act, 1961, with reg....