- (1.) The present appeals have been filed by the Department under Section 260A of the Income Tax Act, 1961 against the consolidated judgment and order dated 16.04.2000, passed by the Income Tax Appellate Tribunal in I.T.A. Nos. 568, 569, 570 & 571/ALL/1999, for the assessment years 1992-93; 1993-94; 1994-95; and 1995-96 respectively.
(2.) On 15.05.2007, a Coordinate Bench of this Court had admitted the appeals on the following substantial question of law:- "Whether on the facts and in the circumstances of the case the Income Tax Officer could not form reason to believe and initiate proceedings under Section 147 of the Income Tax Act on the basis of the report of ADI (Investigation), Allahabad -
(3.) The brief facts of the case are that the Income Tax Officer, Mirzapur completed the assessment for all the four assessment years under consideration by a consolidated assessment order dated 05/31st March, 1998 determining the total income as under:- Assessment Year Amount (Rs.) 1992-93 2,75,940/- 1993-94 2,70,210/- 1994-95 3,75,330/- 1995-96 3,76,640/-;