COMMISSIONER OF INCOME TAX Vs. ASHOK LOGANI

JUDGEMENT

(1.) These appeals are admitted on the following substantial question of law:

(2.) We heard the arguments in detail at the time of admission itself.

(3.) These two appeals pertain to the Assessment Years 2003-04 and 2004-05. They are filed against the common orders dated 21.01.2009 passed by the Income Tax Appellate Tribunal (hereinafter referred to as the Tribunal?) in respect of both the assessment years. In these appeals before the Tribunal, the assessee had challenged the orders of Commissioner of Income Tax (CIT) passed under Section 263 of the Income Tax Act ( the Act? for brevity). Since both the orders under Section 263 of the Act were passed for these two assessment years under identical circumstances, the facts narrated hereinafter would cover both these assessment years.