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Issues involved: Validity of proceedings u/s 263 of the Income-tax Act, 1965.
The High Court considered the validity of proceedings conducted u/s 263 of the Income-tax Act, 1965. The Commissioner invoked section 263 after reassessment proceedings u/s 147 were completed by the Assessing Officer. It was observed that the reasons for reopening the assessment were the same as those for invoking jurisdiction u/s 263. The Tribunal noted that the Assessing Officer, during reassessment, sought an explanation regarding certain transactions, which was provided by the assessee to the satisfaction of the Assessing Officer. Consequently, the Tribunal concluded that the invocation of section 263 was not legally sustainable, leading to the setting aside of the Commissioner's order. The High Court upheld the Tribunal's decision, citing similar precedents where orders u/s 263 were set aside by the Tribunal and upheld by the Court. The High Court found no substantial question of law warranting consideration in the case and thus dismissed the appeal.
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