(1.) By way of this Appeal, the Appellant assessee has challenged the judgment and order dated 31.03.2006 of the Income Tax Appellate Tribunal, Rajkot Bench in ITA No.451/Ahd./2005 for the Assessment Year : 1993 -1994, whereby the Tribunal reversed the decision of CIT (Appeals) and confirmed the order of the Assessing Officer.
(2.) While admitting the matter on 06.03.2007, the following substantial question of law was framed by the Court for consideration : -
(3.) The facts of the case are as under : -