(1.) By way of this appeal, the appellant has assailed the judgment and order of the tribunal whereby tribunal has dismissed the appeal of the department.
(2.) Counsel for the appellant has framed following substantial question of law:-
(3.) Counsel for the appellant has taken us to the judgment of the Supreme Court in Godrej and Boyce Manufacturing Company Limited v. Dy. Commissioner of Income Tax and Ors. AIR 2017 SC 2675 wherein it has been held as under:-