G.C. Gupta, J. - (1.) The subject matter of challenge in the appeal is a judgment and order dated August 31, 2004, passed by the learned Income Tax Appellate Tribunal, "A" Bench, Kolkata, pertaining to the block period commencing from April 1, 1988 upto April 21, 1998, passed in I.T.(SS)A. No. 103/Kol/2003, partly allowing the appeal preferred by the assessee.
(2.) Aggrieved by the judgment and order of the learned Tribunal, the assessee has come up in appeal.
(3.) The following questions of law were formulated at the time of admission of the appeal: "i) Whether the block assessment was valid, competent and justified in law as the seized material did not disclose any undisclosed income in respect of either Rs. 1,59,38,664/ - or Rs. 5,40,000/ - under Sec. 158B(b) read with Sec. 158BB of the Income -tax Act, 1961. ii) Whether on the facts and in the circumstances of the case the Tribunal was competent and justified in making addition/disallowance of Rs. 1,59,38,664/ - or any part thereof which the Assessing Officer and Commissioner of Income Tax Appeal did not make. iii) Whether the disallowance of the expenses of Rs. 1,59,38,664/ or any part thereof was perverse, without lawful basis, vitiated by irrelevant consideration and violative of the principles of natural justice.";