2012 (8) TMI 951

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.... advocates on both sides, we are of the 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 260....