COMMISSIONER OF INCOME TAX Vs. P S MANI

JUDGEMENT

(1.) THIS appeal is filed under Section 260a of the Income Tax Act, 1961 by the Revenue, against the order of the Income Tax Appellate Tribunal, Bench 'c', Chennai in I. T. (SS)A. No. 991/mds/2004 dated 30. 06. 2006, raising the following substantial questions of law:

(2.) WHETHER on the facts and circumstances of the case, the provisions of sec. 158bb (ca) would apply only where returns are not at all filed, or whether it would also apply to cases where the return is filed beyond the specified time limits and is hence invalid?

(3.) WHETHER on the facts and circumstances of the case, the Tribunal was right in holding that there was no undisclosed income for the years in which advance tax had been paid, even though the returns were not filed within the time limit specified u/s 139 (1)?"