PRAKASH ENGINEERING WORKS Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) This appeal under section 260A of the Income-tax Act, 1961, is from an order dated September 18, 2003, passed by the learned Income-tax Appellate Tribunal "A" Bench, Kolkata, in I.T.A. No. 1475 (Kol)/2001 for the assessment year 1994-95 on the following questions:

(2.) Mr. Dudhuria, learned advocate appearing for the Revenue, submits that in view of the letter dated November 21, 1998, issued by Marcandy Prasad Radha Krishna Prasad P. Ltd., the sister concern of the appellant, justifying the imposition of higher rate for conversion charges and as the entire issue has been dealt with by the Tribunal specifically, the order under challenge is just and proper.

(3.) We find that the Assessing Officer, while disallowing the claim of the appellant, had found as under: