2008 (3) TMI 204

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..... r. A. P. Shrivastava, learned counsel for the assessee, and Mr. Sanjay Lal, learned counsel for the Revenue, it is finally heard. 2. The present appeal preferred under section 260A of the Income-tax Act, 1961, involves the substantial questions of law which is formulated as under "(i) Whether the Income-tax Appellate Tribunal is justified in expressing the opinion that the three grounds raised i .....

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..... ould not have been change in the result of appeal. Additionally contends Mr. Shrivastava that it is obligatory on the part of the Tribunal to deal with every factual facet being the last fact finding authority. 5. Mr. Sanjay Lal, learned counsel appearing for the Revenue supported the order passed by the Tribunal. 6. To appreciate the submissions raised at the Bar and the question framed, we hav .....

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..... apart, the Tribunal would have been well advised to deal with the grounds before opining that they are general in nature. 8. In view of the aforesaid, the order passed by the Tribunal in I.T. SS(A) No. 1l/JAB/05, decided on October 16, 2007, is set aside and the matter is remitted to the Tribunal for deciding the same afresh regard being had to the merits and ascribing the cogent and germane rea .....

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