DY CIT Vs. GUJARAT SETCO CLUTCH LTD

JUDGEMENT

(1.) AS common question of law and facts arise in both these appeals, they are heard together and disposed of by this common judgment.

(2.) FELLING aggrieved and dissatisfied with the impugned judgment and order passed by the learned ITAT (hereinafter referred to as 'the Tribunal') in ITA No. 3019/Ahd/1994 for the Assessment Year 1992 -93, the Revenue has preferred Tax Appeal No.438 of 2000 to consider the following substantial question of law;

(3.) WE have heard Shri. K.M. Parikh, learned Advocate appearing for the Revenue as well as Ms. Gargi Vyas, learned Advocate appearing on behalf of the Respondent -Assessee and considered the impugned judgments and orders passed by the learned ITAT.