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Section 147 of the Income-tax Act, 1961 - Income escaping assessment - Non-disclosure of primary facts - Assessment year 1998-99 - For relevant assessment year, assessment of assessee was completed under section 143(3), vide order dated 25-5-2000 - Subsequently, Assessing Officer sought to reopen assessment on basis of one letter dated 28-8-1999 - Tribunal opined that said letter could not constitute new information coming after assessment which had been completed inasmuch as assessment order was passed after date of letter in question - Accordingly, Tribunal quashed reassessment order holding that no new information/material had come to Assessing Officer after completing original assessment to form any belief about escapement of assessee's income and that such a purported belief was entirely based on re-appraisal or re-consideration of material/information already available on record at time of completion of original assessment - Whether, on facts, no substantial question of law arose from Tribunal's order - Held, yes CASE REFERRED TO India and Eastern Newspaper Society v. CIT [1979] 119 ITR 996 / 2 Taxman 197 (SC) [Para 2]. Arvind Verma for the Appellant. Prakash Kumar for the Respondent. JUDGMENT 1. This appeal is directed against the order dated 20-3-2008 passed by the Income-tax Appellate Tribunal in ITA No. 13/D/2003 pertaining to the assessment year 1998-99. The only issue that is sought to be raised in the present appeal arises from the Tribunal's decision that the reassessment proceedings under section 147/143(3) of the Income-tax Act, 1961, were invalid. 2. The Tribunal has examined the facts and circumstances of the case and has arrived at the conclusion that the re-opening of the assessment which had been done under section 147(3) was not justified as no new material had come before the Assessing…

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