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ORDER 1. This appeal challenges the order passed by the Income-tax Appellate Tribunal. The block assessment period from 1997-98 to 2002-03 was under consideration. The appeal was filed by the Revenue, and the Income-tax Appellate Tribunal was requested to quash and set aside the order passed by the Commissioner of Income-tax-I (Appeals), Pune, dated January 2, 2004/February 23, 2004. 2.The grievance of the Revenue was that the assessee is a private limited company. It is in the business of land development including purchasing of land, developing it by dividing into plots. The plots are sold. A search and seizure under section 132 of the Income-tax Act, 1961, was the subject matter of the proceedings. That was carried out on April 11, 2001. In response to the notice under section 158BC, the assessee filed a return declaring total undisclosed income of Rs. 15,57,000. The Assessing Officer completed the assessment under section 158BC(c) of the Income-tax Act by order dated April 29, 2003. He determined the total undisclosed income of Rs. 7,81,85,884 by making the addition of Rs. 7,66,28,884. The assessee, aggrieved by this assessment order carried the matter to the Commissioner of Income-tax (Appeals) who allowed the appeal of the assessee, quashed the order of the Assessing Officer. The Revenue approached the Tribunal and by the impugned order, the Tribunal also dismissed the appeal. 3. It is urged that there are substantial questions of law and specifically those enumerated at paragraphs 5, page 5 of the paper book, arising for determination and consideration in this appeal. 4. We find after perusing this memo of appeal and the order of the Tribunal that the attempt of the Revenue is to have a reappreciation and reappraisal of the factual materials. The only two papers which the Assessing Officer relied upon, namely page 17 of bundle No. 2 and paper No. 55 of bundle No. 2 have been referred to in details. After the seizure, the managing director of the company was required to explain the contents of the paper. The two statements were recorded. The matter has been discussed in detail by the Commissioner of Income-tax (Appeals) and the Tribunal. Upon a perusal of…

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