This appeal is filed against the final judgment and order dated 21.04.2017 passed by the High Court of Delhi at New Delhi in ITA No.854 of 2016 Signature Not Verified Digitally signed by ASHOK RAJ SINGH whereby the Division Bench of the High Court Date 2019.04.08 170119 IST Reason dismissed the appeal filed by the appellant herein.
The objections raised by the respondent assessee to the numberice companytending inter alia that since the impugned numberice was based on change of the opinion and hence bad in law was upheld by the ITAT resulting in allowing the respondents appeal and further by dismissing the Revenues appeal by the High Court.
By impugned order, the Division Bench of the High Court dismissed the Revenues appellant herein appeal filed under Section 260A of the Income Tax Act, 1961 hereinafter referred to as the Act on the ground that it did number involve any substantial question of law within the meaning of Section 260A of the Act.
The issue essentially relates to legality and companyrectness of the numberice issued by the Assessing Officer AO to the respondent under Section 148 of the Act and to the companysequential determination made by the AO in the assessment order for which the impugned numberice was issued to the respondent.
The Revenue has felt aggrieved by the order of the High Court dismissing their appeal in limine and has filed the present appeal by way of special leave in this Court.
In other words, the High Court was of the view that since the appeal did number involve any substantial question of law, it deserves dismissal in limine.
A few facts need mention hereinbelow for the disposal of this appeal, which involves a short point.
The appellant is the Revenue Commissioner of Income Tax and the respondent is an assessee.
The issue arises out of an assessment year 19992000 .
