2014 (10) TMI 785

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..... Being aggrieved and dissatisfied with the impugned judgement and order dated 20.08.2001 passed by the Income Tax Appellate Tribunal, Ahmedabad (ITAT) in Income Tax Appeal No. 38/AHD/1993 for the assessment year 1977-78, the assessee has preferred the present tax appeal with the following substantial question of law: "Whether on the facts and in the circumstances of the case, the Tribunal is righ .....

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..... od adopted by the assessee and worked out an assessment order by applying 10% profit. The appellant preferred appeal before the CIT(A) who upheld the addition made by the Assessing Officer in the second round of proceedings. 2.2 Being aggrieved by the order of the first appellate authority sustaining the additions, the appellant preferred appeal before the ITAT and the Tribunal vide impugned orde .....

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..... dments shall come into force with effect from 1-4-1988 and will accordingly apply to the assessment year 1988-89 and subsequent years. [Section 3(g) of the Finance Act, 1987.] 4.1 We are of the opinion that the interpretation of the Tribunal is erroneous. The reliance placed by the Tribunal on a decision of the Apex Court in also erroneous. In that view of the matter, we are of the opinion that .....

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