(1.) WE have heard learned counsel for the appellant and Sri R.K. Upadhyaya, appearing for the IT Department. The questions sought to be raised for the purpose of this appeal are as follows :
(2.) WE have considered the impugned orders along with the above questions and we do not find any force in the appeal.
(3.) THE AO has passed the detailed order which has been accepted by the appellate authorities and mere non -mention of s. 145 does not vitiate the proceedings because the criteria set out in that section has already been met in the impugned orders.