(1.) BEING aggrieved and dissatisfied with the impugned judgment and order passed by the Income Tax Appellate Tribunal (hereinafter referred to as 'ITAT') dated 06/06/2013 in ITA No. 281/RJT/2012 for the Assessment Year 2006 -07, the revenue has preferred the present Tax Appeal with the following substantial questions of law;
(2.) HAVING heard Shri Pranav Desai, learned Counsel appearing on behalf of the revenue and considering the impugned order passed by the ITAT and the proposed substantial questions of law, the only question, which is raised in the present Tax Appeal, is whether the ITAT is justified in law as well as on fact in deleting the addition/disallowance of Rs.30,71,212/ - made by the Assessing Officer applying the provisions of Section 40(a)(ia) of the Income Tax Act?
(3.) ANOTHER question, which is raised is the initiation of reassessment order under Section 143(3) read with Section 147 of the Income Tax Act.