(1.) The above appeal was preferred by the Appellant against the judgment and order dt. 10th Feb., 2006 passed by the Tribunal 'D' Bench, Calcutta in IT(SS)A No. 185/Kol/2004 in the block asst. yrs. 1996-97 to 2001-02 insofar as the same relates to reconsideration of taxability or otherwise of the sum of Rs. 2,54,32,93,100 received by the Appellant on 1st March, 2006. Thus it appears that the appeal is preferred against portion of the judgment and order of the learned Tribunal by which five several appeals were disposed of. One of the appeals being IT(SS)A No. 161/Kol/2004 was preferred against the order of the CIT passed under Section 263 of IT Act, 1961, dt. 27th Nov., 2006. Above appeal was admitted on the following formulated question of law:
(2.) The short facts relevant for this appeal, are as follows:
(3.) Thereafter the AO made fresh assessment and necessary order was passed in terms of the direction of the learned Tribunal. In the context of the aforesaid factual position the present appeal is being heard by the Court.