COMMISSIONER OF INCOME TAX Vs. VIKRAM A DOSHI

JUDGEMENT

(1.) HEARD rival parties.

(2.) PARTIES to both appeals are different but issues involved are identical. So, one single order will dispose of both appeals.

(3.) THE other questions sought to be raised by the Revenue need no consideration as the issues raised therein are based on transactions which, by no stretch of imagination can be said to be undisclosed transactions falling under S. 158B of the IT Act, since the transactions in question were disclosed in returns which were the subject matter of regular assessment. The same ought to have been assessed in the regular assessment and not in the block assessment. We, therefore, affirm the conclusions or findings recorded by the Tribunal with respect to those transactions referred to in other questions sought to be canvassed, may be for additional different reason recorded herein. In the result, both appeals are partly allowed. The appeals are remanded back to the Tribunal so as to consider only the first question afresh in accordance with the principles of natural justice. No order as to costs.