(1.) These are appeals under Section 260A of the Income Tax Act, 1961 (herein after referred to as 'the Act'). The appellants of the two appeals are husband and wife, are engaged in the same and/or overlapping business, and raise common issues of law. There are minor variations of facts with respect to the two appeals which would be indicated separately, if needed. Both the appeals relate to block assessment for the period AY 1991-1992 to 2000-2001 (upto August 30.8.2001), under the provisions of Section 158BC of the Act.
(2.) The appellants have framed the following substantial questions of law for our consideration in the two appeals:
(3.) There was a search and seizure of the common residence and business premises of the two appellants on 28.6.2000, which concluded with search and seizure of the bank locker in their joint names on 30.8.2000. The appellant had submitted his returns. On a consideration of the entire materials on record, the learned Assistant Commissioner of Income Tax, Patna, being the Assessing Officer, passed order of assessment on 29.8.2002, whereby he assessed the appellant to tax. Aggrieved by the order of the learned Assessing Officer, the appellant preferred appeal before the learned Commissioner of Income Tax (Appeals), Patna, which was disposed of by order dt.20.1.2004, whereby certain reliefs were granted to the appellant, and certain additions were also made. Aggrieved by this order, the appellant as well as the Revenue preferred separate appeals before the learned Income Tax Appellate Tribunal, Patna Bench, which were disposed of by a common order dated 27.7.2007, whereby ; the appeal filed by the assessee was dismissed, and that of the Revenue was allowed in part. Aggrieved by the order of the learned Tribunal, the assessee has preferred the present appeal under the provisions of Section 260A of the Act, and impugned herein.