C I T Vs. BANK OF RAJASTHAN LIMITED

JUDGEMENT

(1.) THESE four appeals involve common questions of law, and are between the same parties, and are, therefore, being decided by common order. Though these are two sets of appeals, one being Appeal No. 12/2005, which has been filed against the order of the learned Tribunal dt. 15.7.2004, while the other three appeals are against the common judgment of the Tribunal dated 29.5.2003, but then the judgment dt. 15.7.2004 simply follows the judgment dated 29.5.2003. Thus these appeals involve common questions of law. Appeal No. 12 was admitted vide order dt. 24.3.2005, by framing the following substantial question of law: Whether in the facts and circumstances of the case, the difference in interest amount accounted for by the assessee on accrual basis in his books of accounts, and the amount actually offered for taxation in computation of income submitted by the assessee should be the subject matter of adjustment under Section 143(1)(a) for raising a demand of tax and additional tax on that basis.?

(2.) WHILE the other three appeals have been admitted vide order dt. 13.12.2005, by framing the following three substantial questions of law:

(3.) IT is not in dispute, that for the relevant period, involved in these appeals, the provisions of Section 18 to 21 of the Income Tax Act as they stood, did stand deleted. However, since much of the controversy is raised on the aspect of effect of deletion of these sections, we think it appropriate to quote the provisions of Section 18 to 21, as they stood earlier, and they read as under: Section 18 Interest on securities (1) The following amounts due to an assessee in the previous year shall be chargeable to income -tax under the head interest on securities: