COMMISSIONER OF INCOME TAX Vs. D KAVERI AMMAL

JUDGEMENT

(1.) THE above tax case appeals are directed against the order of the income-tax Appellate Tribunal in ITA Nos. 1409 to 1411/mds/1999 respectively.

(2.) THE Revenue is the appellant. The assessment years involved in these cases are 1993-1994, 1994-1995 and 1995-1996. The assessee is a partnership firm. The Revenue, aggrieved by the exclusion of certain income which has been clubbed by the assessing officer by invoking the provisions of section 61 of the Income-Tax Act, 1961, has preferred the above appeals by raising the following substantial questions of law:-

(3.) PRECISELY, the point is whether the Memorandum of Understanding, which is the subject matter in the assessment order is irrevocable or not under Section 61 of the Act, which reads as follows:-