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(Judgment of the Court was delivered by T.S. Sivagnanam, CJ.)
1. These appeals have been filed by revenue under Section 260A of the
Income Tax Act, 1961 (the Act) questioning the correctness of the order
passed by the Income Tax Appellate Tribunal, “A” Bench Kolkata in ITA Nos.
801, 802, 286/Kol/2023 for the assessment years 2017-2018, 2018-2019,
2019-2020. The revenue has raised the following substantial questions of
law for consideration:-
(a) Whether on the facts and in the circumstances of
the case, the Learned Income Tax Appellate Tribunal
was justified in law in relying on the decision of the
Hon’ble Apex Court in case of Jindal Steel and Power
Limited in Civil Appeal No. 13771 of 2015 in the
present case whereas the facts and circumstances of
both the cases are distinguishable?
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