S. H. Kapadia, J. - (1.) Leave granted.
(2.) The short question which arises for consideration in this civil appeal is as to what is the scope of enquiry by the Prescribed Authority under Section 10(23C)(vi) read with the third proviso thereto inserted by Finance Act, 1998 w.e.f. 1.4.1999. In this case, Central Board of Direct Taxes (CBDT) being the Prescribed Authority, at the relevant time, rejected the application for approval dated 7.4.1999 vide its order dated 12.10.2004. The said order has been upheld by the impugned judgment dated 24.11.2006 delivered by Delhi High Court in Writ Petition (C) No. 17978/04, hence, this civil appeal.
(3.) Briefly, the facts are as follows :;