DATED

14.08.2014.

THIS ITA, HAVING BEEN HEARD AND RESERVED FOR

JUDGMENT

ON

14.06.2022

COMING

ON

FOR

PRONOUNCEMENT OF JUDGMENT, THIS DAY, P.S.DINESH

KUMAR J, PRONOUNCED THE FOLLOWING:-

JUDGEMENT

These appeals have been admitted to

consider following questions of law:

" a) whether the Tribunal is correct in law in

upholding the action of the assessing officer

in reopening the assessment under Section

147 of the Act for the assessment years

2005-06, 2006-07 and 2007-08 on the facts

and circumstances of the case?

b) Whether Tribunal erred in law in not

holding that there was no reason to believe

that income escaped assessment and all

mandatory

conditions

to

reopen

the

assessment under Section 147 of the Act

were

not

satisfied

on

the

facts

and

circumstances of the case?

3

c) Whether the Tribunal was correct in law in

reversing

the

deletion

made

by

the

Commissioner of Income Tax [Appeals] of the

addition under Section 69B in respect of

alleged unexplained investments made in

properties

of

Rs.

28,75,500/-

for

the

assessment year 2007-08 on the facts and

circumstances of the case? =

2. Brief facts of the case are, the assessee is

an individual who carries out contract works. He

filed ret