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Issues involved: Interpretation of actuarial valuation report, exercise of powers u/s 263 of the Act by Revisional Authority, validity of Tribunal's decision.
Interpretation of actuarial valuation report: The Appellant argued that the Assessing Officer failed to consider the actuarial valuation reports for specific periods, leading to the Revisional Authority's intervention u/s 263 of the Act. However, the Respondent's Senior Counsel highlighted that the actuarial report for a different year was indeed submitted during assessment proceedings, and the Revisional Authority found no legal basis to invoke u/s 263 for that reason. The Tribunal did not address this specific issue, rendering the Appellant's argument irrelevant. Validity of Tribunal's decision: The Appellant conceded that other issues raised in the appeal were adequately addressed by the Tribunal, acknowledging no fault in their handling. Consequently, since the key question regarding the actuarial valuation report did not warrant consideration, the appeals were dismissed for lack of substantial legal questions, with no costs imposed.
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