(1.) The revenue has come up in this appeal challenging the concurrent findings of the order passed by the Commissioner of Income Tax which has been affirmed by the Income Tax Appellate Tribunal, Bangalore in ITA. No. 852/Bang/2000 for the assessment year 1996-97 dated 12.1.2005 raising the following substantial questions of law:
(2.) We have heard the learned Counsel for the parties.
(3.) The facts leading to the filing of tin's appeal are as hereunder: