COMMISSIONER OF INCOME TAX Vs. RAYMOND LTD

JUDGEMENT

(1.) This appeal by the Revenue arises from a decision of the Income Tax Appellate Tribunal dated 22 March 2007; the Assessment Year to which appeal relates being AY 1994-95. The following substantial questions of law are raised by the Revenue:

(2.) Counsel appearing on behalf of the Revenue and the counsel appearing on behalf of the assessee are agreed that Questions (A), (B), (F) and (G) would stand covered in favour of the assessee and against the Revenue for the following reasons:

(3.) As regards Questions (D) and (E), the judgment of the Tribunal would indicate that both the grounds arose in the appeal filed by the assessee against the order of the CIT(A). On Question (D), the Tribunal confirmed the order passed by the CIT(A) in paragraph 74 of its decision while on Question (E), the Tribunal confirmed the order passed by the CIT(A) in paragraph 81. In that view of the matter, since there was no appeal whatsoever by the Revenue on the findings of the CIT(A) on the aforesaid two questions where the Tribunal has confirmed the order passed by the CIT(A), no substantial question of law would arise from the decision of the Tribunal at the behest of the Revenue.