COMMISSIONER OF INCOME TAX DEL vs. RAVINDRA KUMAR JUNEJA

Admit.

The following substantial questions of law arise for consideration:- (a) Whether the Ld. ITAT in the facts and circumstances of the case was correct in law in holding that the reopening of the assessment was not in accordance with the law? (b) Whether the Ld. ITAT in the facts and circumstances of the case was correct in law in holding that even if the reasons for reopening of the assessment are recorded, the same are not legally sustainable inasmuch as the Revenue has failed to produce the records for legal scrutiny of the Tribunal? ITA 1258.2006 Page 1 of 2 . . (c) Whether the order of the Ld. ITAT is perverse as it failed to appreciate and consider that the CIT(A) categorically recorded the finding that ?it is seen that the A.O. had sufficient reasons for reopening the assessment and these reasons were duly recorded and approved by the concerned authority?? The Appellant is directed to file Paper Books within three months in accordance with High Court Rules.

List for hearing in due course. . . . . VIKRAMAJIT SEN, J . . . . . S. MURALIDHAR, J NOVEMBER 21, 2006 tp . . ITA 1258.2006 Page 2 of 2 41