SANJAY OILCAKE INDUSTRIES Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) THIS Reference, though shown to be at the instance of the assessee-applicant in fact involves cross References for Assessment Years 1983-84, 1984-85 and 1985-86. In fact, there are as many as 11 References arising from 7 Appeals before the Tribunal. However, the Tribunal has drawn up a consolidated statement of case as broadly the controversy is divided into two issues.

(2.) IN so far as the assessee-applicant is concerned the following six questions have been raised under section 256 (1) of the Income Tax Act, 1961 (the Act) by Income Tax Appellate Tribunal, Ahmedabad Bench 'c'.

(3.) IT is an accepted position between the parties that the issue raised by the aforesaid six questions at the instance of the assessee stands concluded by a decision in this regard rendered in assessee's own case for Assessment Year 1982-83. In fact the Tribunal has followed its own order for Assessment Year 1982-83 in relation to this issue.