MAHENDRA D JAIN Vs. INCOME TAX OFFICER

JUDGEMENT

(1.) In the present appeal, the appellant (assessee) has impugned before this Court the order passed by the Appellate Tribunal dated 27th July, 2000 pertaining to the Assessment Year 1992-93. The substantial question of law on which the appeal is admitted by this Court is as follows:

(2.) The relevant facts arising in the present appeal are as under:

(3.) We have heard at length the submissions of the Advocates appearing for the assessee. We have not received any assistance from the Advocate for the Department. The Advocate for the assessee has placed very strong reliance on the decision which was also relied upon by him before the Tribunal i.e. the decision of the Hon'ble Apex Court in the case of Commissioner of Income Tax, Patiala Vs. Piara Singh reported in (1980) 124 ITR 40 (SC). It is, therefore, necessary for us to set out the facts and discussion found in the said judgment at some length.