RICKMAN ALUMINIUM PVT. LTD. Vs. INCOME TAX OFFICER

JUDGEMENT

(1.) BY way of both these appeals, the appellant of Tax Appeal No. 358/2006 has challenged the judgment and order dated 28.6.2005 passed in ITA No. 2982/Ahd/2003 for AY 1997 -98, whereas, the appellant of Tax Appeal No. 359/2006 has challenged the judgment and order dated 28.6.2005 passed in ITA No. 2983/Ahd/2003 for AY 1998 -99.

(2.) WHILE admitting these appeals on 4.9.2006, in both these appeals, the following substantial question of law has been framed by this Court:

(3.) THE return of income was filed on 30.11.1998 showing total income of Rs. NIL. The return was processed u/s. 143(1)(a) on 15.2.1999 at NIL income. The notice u/s. 143(2) was issued on 17.6.1999 picking up the case in scrutiny. A notice under sec. 142(1) was issued on 31.8.99 calling for specific details. Thereafter, after considering the material on record, the assessment order came to be passed. Against the said order, an appeal before the CIT(A) has been preferred which came to be partly allowed except in AY 1998 -99 he appeal came to be dismissed. Against which, an appeal before the Income -tax Appellate Tribunal came to be preferred by the assessee which came to be dismissed. Hence, both these appeals before this Court by the assessee.