Suresh Kait, J.

1. In these appeals, though, various questions of law are proposed, it is accepted by learned Counsel for the Appellant that the main issue is about the reopening of the proceedings under Section 147 read with Section 148 of the Income Tax Act. The decision in respect of other issues raised would depend upon the outcome of the appeals. These appeals are accordingly admitted on the following substantial question of law.

1. Whether on the facts and law, the Tribunal was right in holding that the initiation of proceedings under Section 147 read with Section 148 of the Act in all the three years is justified?

2. With the consent of learned Counsel for the parties, we have heard the matter finally at this stage.

3. The issue raised by the Assessee had been adjudicated by the Tribunal wherein Accountant Member of the Tribunal disagreed with the order passed by the Judicial Member. Therefore, the matter was referred to third member. The Third Member of Tribunal has restored the issue relating to claim of the deduction, while concurring with the view taken by the Judicial Member on the following of aspects:

1) That initiation of proceedings under Section 147 read with Se