POPULAR MINI FINANCIERS Vs. CIT

JUDGEMENT

(1.) THESE appeals under section 260A of the Income Tax Act, 1961, (Act in short), are directed against a common decision rendered by the Tribunal, affirming orders issued by the CIT under section 263 of that Act. At the request of the learned counsel for the appellant, paper book in IT Appeal No. 166 of 2012 is looked into treating that as a lead case. No dispute is raised on behalf of the Revenue to this course being adopted by them. Heard the learned counsel for the appellant and the learned senior counsel for the Revenue.

(2.) THE three substantial questions of law suggested in the appeal memoranda, taken together, only point to the plea that, the assessments having been completed after obtaining directions from the Addl. CIT under section 144A and because such state of affairs were in the know of the CIT, there was no ground to invoke section 263 on the premise that the assessment orders are erroneous insofar as it is prejudicial to the interests of the Revenue. We do not now say that this, by itself, would not give rise to substantial questions of law. It would depend upon the sequence of events which would note hereunder.

(3.) THE Tribunal considering the materials on record, affirmed the finding of the CIT. The reasoning that it has set forth in the order impugned; also making reference to the material particulars as disclosed by the files and the different materials placed before the Tribunal by the assessee; does not generate any question of law, much less a substantial question of law, for admission of these appeals. Hence, these appeals fail.