2003 (8) TMI 9

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....rises out of the Tribunal's order dated September 18, 2002: "Whether, on the facts and in the circumstances of the case, the Tribunal was justified in setting aside the reopening of the fact that proceedings initiated were on the basis of vague and non-specific information, which otherwise is against the material on record?" The facts of the case are that after an intimation was sent under secti....

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....ich could not have given any foundation for assessing the validity of reassessment proceedings. The question suggested about the validity of reassessment proceedings which has been held against the Revenue is a substantial question of law. However, we find from the order of the Tribunal that the Tribunal has not rested its decision solely on the basis of the invalidity of the proceedings under se....