- (1.) BY way of this common judgment, all the above three appeals are being disposed of since the common question of law is involved in all these case.
(2.) THE short question in these appeals raised by the Revenue is as to whether the Income Tax Appellate Tribunal (for short as Tribunal ) was correct in quashing the assessment framed under Sections 143 (3) and 147 of the Income tax Act, 1961 (for short as Act ) ignoring the provisions of Section 149 (1) (a)of the Act.
(3.) BRIEF facts leading to dispute are that the original assessments for the assessment years 1991-92, 1992-93 and 1993-94 were completed on 28th october, 1993, 26th November, 1993 and 18th January, 2004 respectively under section 143 (3) of the Act at an income of Rs. 3,27,170/-, Rs. 7,84,160/- and rs. 6,21,830/- respectively. Subsequently, the Assessing Officer came to know that ratable value in respect of properties bearing No. B-6 and B-7, Asaf Ali road, New Delhi owned by the Assessee have been determined at Rs. 10,28,900/- by the Municipal Corporation of Delhi against Rs. 3,61,000/- declared by the assessee on the basis of actual rent received. Thus, the Assessing Officer reopened the assessment for these three assessment years by issuing notice under section 148 of the Act on 31st March, 2000.;