(1.) ADMIT. The following substantial question of law is framed:-
(2.) AS we have heard learned counsel for the parties, we proceed to pronounce our decision on the aforesaid question.
(3.) THE tribunal in the impugned order has not referred to the factual matrix or given any finding either affirming or contrary to the finding recorded by the Assessing Officer/CIT (Appeals). THE tribunal referred to the decision of the Jaipur Bench in the case of Jagvijay Auto Finance Pvt. Ltd. Vs. ACIT, 52 ITD 504 and held as under:-