(1.) Heard Mr. D.D. Chopra, learned counsel for the appellants and Mr. P.J. Pardiwala, Senior Advocate appearing for respondent in Income Tax Appeal No.32 of 2006. In other appeals, Mr. Waseequddin Ahmad has adopted the arguments advanced by Mr.P.J. Pardiwala.
(2.) The afore-captioned appeals have been preferred by the Revenue questioning the correctness of the Judgment passed by the Tribunal dated 31st August, 2005, whereby the Tribunal has upheld the validity of the proceedings initiated under Section 16 of the Gift Tax Act, 1958 [hereinafter referred to as the 'Act' for the sake of brevity] but has deleted the charge to gift tax that was levied by the Assessing Officer.
(3.) While entertaining and admitting the appeal on 19.1.2006, the following two questions have been formulated:-