2005 (2) TMI 36

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....eendran C.J.-These appeals under section 260A of the Income-tax Act, 1961 ("the Act" for short), are filed against the common order dated September 2, 2004, passed by the Income-tax Appellate Tribunal, Jabalpur Bench, in I.T.A. No. 108/JBP/2001 and I.T.A. No. 91/JBP/2001, respectively, relating to the assessment year 1994-95. The appeals have been admitted as the following common question of law a....

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....h the parties, I am of the view that there is no bona fide of the assessee. The circular is not applicable and no mitigating circumstances are there. In these circumstances, the order of the Assessing Officer is upheld and the order of the Commissioner of Income-tax (Appeals) is set aside. 12. In the result, both the appeals are allowed." No other reasons are forthcoming in the order of the Trib....