(1.) HAVING heard learned counsel for the parties in this appeal under Section 260A of the Income Tax Act, 1961 (Act, for short), which pertains to the assessment year 2001-02, we formulate the following substantial question of law:-
(2.) AS we have heard learned counsel for the parties, we proceed to pronounce our decision on the aforesaid substantial question of law.
(3.) SUBSEQUENTLY , the Assessing Officer vide reasons recorded on 24th August, 2006, issued a re- assessment notice under Section 148 of the Act. For the sake of convenience, the "reasons to believe" recorded by the Assessing Officer are reproduced below:-