@JUDGMENTTAG-ORDER
1. It is agreed between the learned counsel for the parties and we are also satisfied that the following questions of law would arises for our consideration:-
1. Whether the initiation of reassessment proceedings in a case where the assessment was framed u/s 143(1)(a), in the absence of approval having been grated by the Joint Commissioner of income tax as envisaged u/s 151, of the income tax Act, 1961 is without jurisdiction and therefore invalid?
2. Whether definition of Commissioner as defined u/s 2(16) of the Act would include the Addl. Commissioner, Joint Commissioner and Deputy Commissioner, as defined u/s 151 of the income tax Act and that the interpretation would be founded/affected by the decision rendered in Berger''s case?
Admitted.
In the facts and circumstances of the case, Registry is directed to list the aforesaid appeal for hearing within six months.
