(1.) The appellant is challenging the judgment and order passed by the ITAT, Panaji, dated 28/12/2005. The appeal was admitted and the following substantial question of law was framed:
(2.) The facts relevant for deciding this appeal are as under:
(3.) An application was filed by the appellant seeking leave of the Court to rely on five documents. The said application was allowed and the appellant was permitted to file additional compilation of five documents namely: Deed of Partnership dated 2/9/1991, Certificate of Registration of Firm dated 6/9/19991, Deed of Rectification dated 9/4/1992, Letter dated 28/7/1994 issued by the Income Tax Officer, Ward-4, Margao and the letter dated 20/10/1994 addressed by M/s. Menezes Fernandes Enterprises.