(1.) HEARD the learned counsel for the appellant and the learned counsel for the Respondent.
(2.) BY the above appeal, the appellant Revenue is seeking to raise the following three substantial questions of law :
(3.) MR . Gopal, the learned counsel for the respondent, pointed out that in the case of Chaturbhuj Dwarkadas Kapadia vs. CIT (2003) 180 CTR (Bom) 107 : (2003) 260 ITR 491 (Bom) wherein almost identical issues were involved and the same was also relied upon by the Tribunal in its order.