A.M. Sapre, J. - (1.)THE decision rendered in this appeal shall govern the disposal of other connected appeals being ITA No. 48 of 2001 (N. Khanchand Khatri v. CJT), IT Ref. No. 49 of 2001 (N. Khanchand Khatri v. CIT) and ITA No. 50 of 2001 (N. Khanchand Khatri v. CIT) as all these appeals involve common issues and, secondly, they are filed by the same assessee except the difference being that these appeals arise out of different assessment years and were disposed of by a common order by the Tribunal, Indore.
(2.)THE present appeal is filed under Section 260A of the IT Act, 1961, which arise out of order dt. 12th April, 2001, by the Tribunal, Indore, in ITA Nos. 216, 217 and 218/Ind. of 1996.
They relate to the asst. yrs. 1987-88, 1988-89 and 1991-92. It appears that on 13th Sept., 1990, a search operation was carried out in the premises of the assessee resulting in seizure of several incriminating documents. This led to issuance of notices to the assessee under Section 148 of the Act by the AO in relation to the aforementioned assessment years for reopening of the cases. In these proceedings some unexplained cash credit entries in the books as also the unexplained source of money was noticed by the AO on the strength of seized documents. The assessee was asked to reply and explain these entries. The assessee not only challenged the very action of the AO in issuing the notice under Section 148 of the Act but also gave his explanation justifying the source of income in relation to these disputed entries. Since the AO rejected both the objections of the assessee and hence the matter travelled up to the Tribunal partly at the instance of the assessee and partly at the instance of the Department. By the impugned order, the Tribunal rejected the contention of the assessee and upheld the additions made by the AO and affirmed by the CIT(A). It is against this order, the assessee has felt aggrieved and filed this appeal.

Heard Shri Joshi learned counsel for the appellant.

(3.)HAVING heard learned counsel for the appellant (assessee), and having gone through the impugned order of the Tribunal, we find no merit in this appeal worth admission. In our considered view, the appeal does not involve any question of law much less substantial question of law--a prerequisite for entertaining the appeal.
The submission of learned counsel for the appellant that there was no material on record to issue notice under Section 148 of the IT Act for reopening of the cases for the years in question and that in the absence of any reasoning not being communicated to the assessee as to why the cases are being reopened vitiates the notice, has no substance. As rightly concluded by the Tribunal, the very act of conducting a raid operation in the premises of the assessee which resulted in seizure of several incriminating documents, itself is more than sufficient material to issue notices under Sections 147 and 148 for reopening of the cases already decided. It was a fact well within the knowledge of the appellant (assessee) and hence it cannot be successfully urged by the appellant that there was no material for initiating action under Section 147/148 of the Act.