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2013 (8) TMI 1139

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....e heard the learned counsel appearing for the appellant and gone through the judgment and order of the learned Tribunal. This appeal is sought to be admitted on the following suggested questions of law: 1. "Whether, on the facts and in the circumstances of the case and in law, the Tribunal is correct in holding that the order of reassessment as null and void? 2. Whether on the....

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....e has been an escapement of income." In view of the aforesaid fact finding, it is difficult for us to admit this appeal, as there is no element of law involved. Further, the learned Tribunal had taken a correct view that an audit opinion in regard to the application or interpretation of law cannot be treated as information for reopening the assessment under Section 147(b) of the Income Tax A....