COMMISSIONER OF INCOME TAX Vs. JAIPUR GOLDEN TRANSPORT

JUDGEMENT

(1.) The present appeal has been filed under Section 260A of the Income Tax Act,1961 (hereinafter referred to as "Act") challenging the order dated 27th November, 2009 passed by the Income Tax Appellate Tribunal (in short "Tribunal") in ITA No. 783/Del/2009 for the Assessment Year 2003-2004.

(2.) In the present appeal, the revenue has raised a large number of questions of law which are reproduced hereinbelow:-

(3.) However, we are of the view that the aforesaid questions No. (i), (ii), (iv), (v), (vi) and (viii) are essentially questions of fact, on which both the Commissioner of Income Tax (Appeals) [in short, "CIT(A)"] and the Tribunal have given concurrent findings of fact against the revenue. We are also of the view that both the CIT(A) and the Tribunal have given cogent reasons for arriving at their factual conclusions. Consequently, questions No. (i), (ii), (iv), (v), (vi) and (viii) do not arise for consideration in the present proceedings.