LT FINANCE LIMITED Vs. DCIT

JUDGEMENT

(1.) By these two appeals filed under Sec. 260-A of the Income Tax Act, 1961 (for short "I.T. Act, 1961"), the appellant - assessee takes exception to the common Judgment and Order dated 5th May, 2015, passed by the Income Tax Appellate Tribunal (for short "ITAT"). The ITAT, by the impugned order, upheld the order of the CIT (A) who inter alia held the gain arising to the assessee on account of securitization of lease receivables and credited to the ProfitLoss Account of the assessee was a taxable receipt in the current assessment year. Income Tax Appeal No. 256 of 2016 is with reference to A.Y. 2002-03 and Income Tax Appeal No. 267 of 2016 is with reference to A.Y. 2003-04.

(2.) In the Memo of Appeal of Income Tax Appeal No. 256 of 2016 what is submitted is that the impugned order gives rise to the following substantial questions of law, which read thus:

(3.) In the Memo of Appeal in Income Tax Appeal No. 267 of 2016, identical questions are raised except that the Assessment Year is different and the amount mentioned therein is also different. Barring this, the questions are identical. Since both the appeals are factually similar and common questions of fact and law arise in both the appeals, they are being disposed of by this common judgment. For the sake of convenience, we shall refer to the pleadings and facts as set out in Income Tax Appeal No. 256 of 2016.