NEO TRUST Vs. INCOMETAX OFFICER

JUDGEMENT

(1.) AS in the present group of appeals, substantial questions of law, to some extent, are interconnected and they are also common in certain group, they are being considered simultaneously. We may record that in order to appreciate the respective questions formulated in the respective matters, the questions can be reformulated and thereafter based on the answer, in facts of each case, the ultimate decision can be recorded.

(2.) IN our view, mainly two substantial questions of law would arise in the present group of matters as referred to hereinafter and to be specific in the first group of matter, comprising of Tax Appeal No.20 of 2001, ITR No.28 of 2000, ITR No.25 of 2003, ITR No.74 of 1996 and ITR No.141 of 1996, following question would be required to be considered:

(3.) WHEREAS , in the second group of ITR No.42 of 2000, ITR No.43 of 2000, ITR No.44 of 2000 and Tax Appeal No.141 of 2001, the substantial question of law which may be required to be considered, would be as under:" Whether on facts and circumstances of the case, the Tribunal was right in taxing income of the Assessee holding it as real income of the Assessee -