1992 (11) TMI 75

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..... following two questions to this court : " 1. Whether, on the facts and in the circumstances of the case, the Tribunal was correct in setting aside the order passed under section 263 by the Commissioner of Income-tax ? 2. Whether, on the facts and in the circumstances of the case, the Tribunal was correct in holding that the order of the Income-tax Officer had got merged with the order of the Com .....

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..... ded to be established through detailed enquiries and investigations. The order of the Income-tax Officer was, in the opinion of the Commissioner of Income-tax, erroneous and prejudicial to the interests of the Revenue. He, accordingly, cancelled the order with the direction that the Income-tax Officer should reframe the assessment after making detailed enquiries in respect of these cash credits an .....

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..... that after the decision of the Income-tax Appellate Tribunal, the Income-tax Officer initiated proceedings under section 147 of the Act and the assessment of the assessee was reopened and the Income-tax Officer, vide his assessment order dated March 27, 1986, accepted the explanation of the assessee relating to the cash credit of Bansidhar Ram Gopal. Thereafter, the assessee filed an appeal before .....

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