- (1.) We have heard learned counsel for the parties and perused the impugned order.
(2.) Vide order dated 10.08.2017, this Court had permitted the appellant to examine as to whether the oral arguments were advanced on substantial question No.3 raised in the Memo of Appeal filed before the High Court under Section 260A of the Income Tax Act, 1961.
(3.) An affidavit has been filed on behalf of the appellant in which it has been stated that the issue of powers of Commissioner (Appeals) had come in appeal under Rule 46A and were specifically raised before the High Court.;