(1.) This appeal under Section 260-A of the Income Tax Act, 1961 (for short "the Act") is at the instance of the Revenue and is directed against the order dated 28.06.2018 passed by the Income Tax Appellate Tribunal, Surat Bench, Surat in ITA No.1356/AHD/2014/SRT for the assessment year 2011-12. By the impugned order the Appellate Tribunal dismissed the appeal preferred by the Revenue and thereby affirmed the order passed by the Commissioner of Income Tax (Appeals)-II, Ahmedabad in CIT(A)-II/CC.1/432/2013-14. The Revenue has proposed the following substantial questions of law :
(2.) The facts giving rise to this appeal may be summarized as under :
(3.) This appeal involves the interpretation of Section 271AAA of the Act. Section 271AAA of the Act reads thus :