AdvertisementCIT (Exemption) Vs B.P. Poddar Foundation For Education (Calcutta High Court) The Revenue filed an appeal under Section 260A of the Income-tax Act, 1961 against the order of the Income Tax Appellate Tribunal for Assessment Year 2009-10. The substantial questions of law concerned whether additions made in reassessment proceedings on issues not forming part of the recorded reasons for reopening under Sections 147 and 148 were sustainable after insertion of Explanation 3 to Section 147 by the Finance Act, 2009, and whether the Tribunal had correctly applied the decisions in Jet Airways (I) Ltd. a...