- (1.) Heard Sri Shakeel Ahmad, learned counsel for the appellant and Sri Piyush Agrawal and Sri Manu Ghildyal, learned counsel for the department as also perused the record.
(2.) This set of appeals have arisen from the common order of the Tribunal dated 30.07.2008 in departmental appeals no. 193 to 196-Alld/2007 for the assessment year 1992-93 to 1995-96; Cross Objections filed by the assessee in the aforesaid departmental appeals being C.O. No. 43, 44, 45 and 48 and; assessee's appeals no. 257 to 260/Alld/2004 for the assessment year 1992-93 to 1995-96.
(3.) These appeals were admitted on the following questions of law:- "(A) Whether upon the facts and circumstances of the case the Tribunal was justified in reversing the well considered order of C.I.T. (Appeal) quashing the notice issued to appellant u/s 148 of the Income Tax Act, only applying provisions of Section 55-A and 142-A-(i) overlooking fact that the said notice U/s 148 of the Act challenged inter alia on the grounds of in sufficient reason for issuing the said notice? (B) Whether upon the facts and circumstances of the case the nearly 3 years old report of I.T.I. and the report of D.V.O. can be termed as information for issue of notice U/s 148 of the Act? (C) Whether upon the facts and circumstances of the Tribunal was justified in confirming the order of C.I.T. Appeals sustaining the addition of Rs. 6,70,441/- as unexplained investment in the building? (D) Whether upon the facts and circumstances of the case the Tribunal was justified in allowing the addition of Rs. 6,67,395/- in part claimed as deduction made by the wife of assessee, in part ignoring the fact that the credit worthiness of the donars to Smt. Brij Kumari Rai and their identity was proved before the Lower Authorities?" ;