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TMI Blog2016 (10) TMI 1049X X X X Extracts X X X X X X X X Extracts X X X X ..... 1 (the Act) challenges the order dated 30th August, 2013 passed by the Income Tax Appellate Tribunal (the Tribunal). The impugned order relates to Assessment for block period 1991-92 to 2000-01 and 2001-02(part). 2. The question urged by the Revenue before us for our consideration is as under : "Whether the Tribunal erred in law in ignoring the second provision to Section 158BFA of the Act?" 3 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing where Mr. Tejveer Singh, learned Counsel for the Appellant Revenue has appeared in Director of Income Tax (International Taxation) vs. Credit Agricole Indosuez 2015 (377) ITR 102, had observed as under : "In matters of tax, justice requires that there must be certainty of law which presupposes equal application of law. Thus, where the issue in controversy stands settled by the decisions of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... BI dated February 4, 2015 [2015] 375 ITR 20 (Bom); I.T.A. No. 330 of 2013 DIT v. Citibank N.A. dated March 11, 2015 - [2015] 377 ITR 69 (Bom))." In spite of the above and some more orders to the above effect the Officers of the Revenue appear to be unmindful of the above and only seek adjournment at the time of the hearing to put in an affidavit before this Court." 5. In the above view, the app ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ble to put any facts on record in respect of the order of the Tribunal in Super Metal Industries (supra) particularly whether it was accepted or not. 7. In the above view, it must be inferred that the same has been accepted as no evidence of it being challenged in Court or even any distinguishing features on facts are pointed out to us. Therefore, the question as raised does not give rise to any ..... X X X X Extracts X X X X X X X X Extracts X X X X
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