PIYUSH AGRAWAL,J. - (1.) The present appeals have been filed against the common order dated 7.12.2015 passed in ITA No. 04 & C15/Alld 2012 for the Assessment Year 2005-06 & 2007-08 passed by the Income Tax Appellate Tribunal, Allahabad, Bench Allahabad.
(2.) The aforesaid appeals on 3.5.2016 was firstly admitted on question No. B, which reads as under: "(B) Whether on the facts and the circumstances of the case, the order of the Income Tax Appellate Tribunal was correct in Law holding that Section 80-IB(10) which is substituted w.e.f. 1.4.2005 is not applicable to the project approve before 01.04.2004. The provision of Section 80(IB)(10)(a)(i) is as such applicable for the all projects which has been approved by the local authority before 1.4.2004."
(3.) Thereafter, on 11.1.2017 this Hon'ble Court accepted and admitted one more question of law mentioned as 'C' in memo of appeals, which reads as under: "Whether on the facts and in the circumstances of the case, the order of the Income Tax Appellate Tribunal was correct in law holding that there is change of opinion by the Assessing Officer. As such, there is no change of opinion as information regarding completion of project has been collected by the Assessing Officer is a new information and Assessing Officer had correctly applied the provision of Section 147/148 for reopening the assessment of A.Y. 2007-08." ;