CIT Vs. MANSAROVER IMPEX (REGD.)

JUDGEMENT

(1.) THE Revenue challenges order dt. 10 -4 -2012 passed by Tribunal, Chandigarh Bench A, Chandigarh on seven questions, styled as substantial questions of law, which read as follows:

(2.) WE would, before dealing with the controversy, like to impress upon the Department that it must take care in framing "substantial questions of law", as it is the quality of a question and not their quantity that invites attention of a Court. We have come across various appeals where questions of fact, howsoever small, are sought to be altered into a substantial question of law. In the present case the only question that may arise, has been divided into seven different questions.

(3.) WE have heard counsel for the appellant, perused the impugned orders and find no reason to hold that any question of law, much less a substantial question of law, arises for adjudication. A perusal of orders passed by the Tribunal and the Commissioner (Appeals) reveals that after due consideration of the entire gamut of the dispute, including the remand report forwarded by the AO, a clear finding has been recorded, from the chart filed by the assessee that the assessees sister concern has charged higher rates from the assessee as well as from all other entities, to which it supplied similar finished goods. In order to place our conclusion in its correct perspective, it would be appropriate to reproduce a relevant extract from the order passed by the Commissioner (Appeals):