G. Chowdhury, J.M. - (1.)THE Revenue has filed these appeals for the asst, yrs. 1991-92, 1992-93 and 1993-94 against the consolidated order passed by the learned CIT(A).
(2.)The common ground raised by the Revenue in all the appeals is that the learned CIT(A) was not justified in quashing the reassessment proceeding in view of the amended provision of Section 147 of the Act.
While framing assessment for the asst. yr. 1994-95, it was noticed by the AO that the assessee had invested towards construction of the house of Rs. 2,96,405 in the asst. yr. 1991-92, Therefore, the case was referred to the Departmental Valuation Officer (DVO) for estimating the cost of construction. The DVO estimated the cost of construction. Since there was difference in the cost of construction as per the report of the DVO in comparison with the cost shown by the assessee, the assessments were reopened for the asst. yrs. 1991-92 to 1993-94. The AO made additions as unexplained expenditure towards cost of construction under Section 69C of the Act in respect of the difference of the aforesaid two amounts.

(3.)BY the impugned order, the learned CIT(A) held that the reopening of the assessments on the basis of the DVO's report was not proper. Against the said finding, the Revenue is in appeal before the Tribunal in all the three years.