COMMISSIONER OF INCOM TAX Vs. WIPRO FINANCE LIMITED

JUDGEMENT

(1.) IN these two appeals, the Appellant-Revenue has challenged the legality and correctness of the orders dated 21-3-2003 and 31-5-2001 passed by the Income-tax Appellate Tribunal (hereinafter referred to as the "tribunal") respectively in IT (SS)A No. 183/bang/2002 and it (SS)A No. 4/b/99. Though respondent-assessees in these appeals are different, the substantial questions of law involved in these appeals are same. Therefore these two appeals are disposed of by this common judgment.

(2.) STATED in nutshell the facts leading to these two appeals are as under :

(3.) THOUGH the Appellant-Revenue has formulated in each appeal as many as four substantial questions of law, only two of them need be considered by us for our decision in view of the fact that the Tribunal disposed of the appeals holding that it had jurisdiction to entertain the appeals and both the Block Assessment Orders impugned therein were barred by limitation. Therefore, the two substantial questions of law which are to be considered for our decision in these two appeals read as under :