TMI Blog1966 (7) TMI 1X X X X Extracts X X X X X X X X Extracts X X X X ..... KHAN. JUDGMENT The judgment of the court was delivered by SOMNATH IYER J.--The question of law which the Appellate Tribunal was directed by this court to refer under section 66(2) of the Indian Income-tax Act, at the instance of the assessee, reads : " Whether the order of the Tribunal discloses that it had applied its mind to the facts of the case and come to its own independent conclusi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... fell within the enunciation made by the Supreme Court in Omar Salay Mohamed Sait v. Commissioner of Income-tax, in which the Supreme Court expressed the view that, since the Income-tax Appellate Tribunal is a fact-finding Tribunal, its conclusions should be reached after due consideration of the evidence and that its order should disclose the questions which arose for determination, the evidence ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essee is that we should say that the Tribunal did not apply its own mind to the facts of the case and it did not reach its own independent conclusions on any of the questions arising in the appeal and that, therefore, the order of the Appellate Tribunal invites the criticism that it is not in accordance with law. We are of the opinion that this submission made by Mr. Srinivasan is unanswerable. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ribunal agreed with the conclusions reached by the Appellate Assistant Commissioner. It is clear from Omar Salay Mohamed Sait's case, that the order made by the Income-tax Appellate Tribunal should be a sufficiently comprehensive and self-contained order from which it should be possible to ascertain all the relevant facts and the questions arising in the appeal. The order should similarly disclo ..... X X X X Extracts X X X X X X X X Extracts X X X X
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