GADODIA ELECTRONICS PVT LTD Vs. CIT

JUDGEMENT

(1.) Gadodia Electronics Pvt. Ltd. has filed the present appeal under Section 260A of the Income Tax Act, 1961 (for short, 'the Act') against the impugned order dated 25th August, 2010 passed by the Income Tax Appellate Tribunal (for short, 'the Tribunal') in ITA No. 746/Del/2010 pertaining to the assessment year 1994-95. After hearing counsel for the parties, we frame the following substantial question of law:-

(2.) With the consent of the parties, we have heard the arguments and proceed to decide the appeal.

(3.) There have been several rounds of litigation and therefore, it is appropriate to state the facts in some detail. The assessee had sold the aforesaid property consisting of land and factory building for Rs. 17.50 lakhs during the assessment period 1994-95. As provisions of Chapter XXC of the Act were then applicable, the appellant had applied for permission and vide certificate dated 22nd March, 1994, permission for sale was granted by the appropriate authority under Section 269UL (3) of the Act. The appropriate authority did not find and hold that the sale consideration was understated.