(1.) INCOME -tax Appellate Tribunal, Guwahati Bench (hereinafter referred to as "the Tribunal") by which the assessments of the respondent -assessee for the asst. yrs. 1999 -2000 and 2000 -01, respectively, have been set aside on the ground that the same are barred by limitation. The appeals have been admitted on the following substantial questions of law :
(2.) THOUGH the above questions framed have been sought to be reformulated by the appellants at the hearing we did not find any substantial difference in the questions as framed by the Court and those suggested on behalf of the appellants. We, therefore, proceed to consider the appeals on the questions of law already framed, as noticed above.
(3.) THE brief facts that will be required to be noticed for an effective adjudication of the issues arising in the two appeals may now be stated.