D.A.MEHTA - (1.) Heard Mr.K.H.Kazi, learned Advocate for the applicant and Mr.M.R.Bhatt, learned Senior Standing Counsel for the respondent.
(2.) The appellant has proposed as many as seven questions, however, the following proposed question is the question which would take care of the controversy between the parties and arises for determination: "Whether, in the facts and under the circumstances of the case, the decision of the ITAT was not perverse in as much as firstly it does not consider the arguments advanced on behalf of the Appellant and secondly the impugned order is not at all reasoned and speaking order, thirdly the impugned order is incoherent and vague and fourthly it does not deal with all the grounds raised challenging various additions on the merits "
(3.) In so far as assessee's challenge to issuance of authorisation of search and legality of search u/s.132 of the INCOME TAX ACT, 1961 (the Act) is concerned, it is not necessary to enter into any discussion as regards the same in this appeal in light of the fact that a separate petition being Special Civil Application No.14104 of 2005 has already been preferred by the assessee.;