COMMISSIONER OF INCOME TAX Vs. S.S. EMBROIDERS

JUDGEMENT

(1.) By this common order, we shall dispose of IT Appeal Nos. 201 and 202 of 2012, preferred by the appellant. The two appeals pertain to asst. yrs. 2005-06 and 2006-07.

(2.) This appeal by the Revenue under s. 260A of the IT Act, 1961 (for short, the 1961 Act) has been filed against order dt. 23rd April, 2012 (Annex. A-3) passed by Tribunal, Amritsar in ITA No. 358/Asr/2010 for the asst. yr. 2006-07, on the following questions of law:

(3.) Notwithstanding formulation of so-called 'substantial questions of law' in para 13 of this appeal by the Revenue, which are neither happily worded nor reflect the real controversy, following substantial question of law is formulated for determination: