(1.) Heard the learned counsel for the appellant and the learned counsel for the respondent.
(2.) This appeal by the Revenue is directed against the order passed by the Income Tax Appellate Tribunal in I.T.A.No. 651/Mds/2001 dated 13.10.2006, confirming the order passed by the Commissioner of Income Tax (Appeals) setting aside the reopening of the assessment for the year 1991-199 The above tax case appeal has been admitted on the following substantial questions of law:
(3.) The assessment for the said year was originally completed under section 143(3) of the Income-tax Act, 1961 on 29.1993 and was reopened by issuing notice under section 147 of the said Act in the year 1997. The reason for reopening the assessment was based upon a report submitted by the Departmental valuer.