TaxTMI 
TaxTMI 
1966 (7) TMI 1
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....is 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 conclusion ? " Two contentions were raised by the assessee before the Income-tax Appellate Tribunal. One was that the yield of the groundnut kernel was wron....
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....e 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 available on record and the findings reached on such evidence. Mr. Srinivasan for the assessee contends that the Appellate Tribunal merely states that ....
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.... 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. The Tribunal did not, as required by law, of which there was an elucidation by the Supreme Court, discuss the evidence upon which the assessee depended, o....
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.... 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 disclose what were the contentions urged before the Tribunal and should state why and for what reason those contentions were repelled. Judged by these standards ....