COMMISSIONER OF INCOME TAX Vs. HYDROCARBONS INDIA LTD

JUDGEMENT

(1.) AT the outset, we would like to point out that the registration of the captioned reference represents a comedy of errors in the sense that even though both, the assessee and the Revenue, have sought a reference of various questions of law, a single reference has been registered and placed before us. This apart, as per the paper book made available to us, the captioned reference is entitled as : Hydro Carbons India Ltd. vs. CIT, whereas the cause list shows the title in the reverse i.e. CIT vs. Hydro Carbons (P) Ltd. (ONGC).

(2.) THE reason we gave this preparatory note is to avoid any confusion being caused on reading of our order. We are, thus, called upon to deal with two references involving two (2) sets of questions involving five (5) questions each. The facts which are required to be noticed for disposal of the captioned references are briefly as follows.

(3.) WE had put the last part of the Tribunal's reasoning to Mr. Syali who appears for the assessee. Mr. Syali has accepted before us that he does not wish to rely upon any additional material apart from that which is already on record. Even otherwise, the Tribunal has given no clue as to what are these additional facts which require investigation.