Remand for fresh consideration where connected litigation required consistent reconsideration on the same factual basis.

The Tribunal's order and the Commissioner of Income-tax (Appeals)' order were set aside and the matter was remanded for fresh consideration. The court noted that the dispute arose from the same factual matrix as connected matters and that the Supreme Court had subsequently remanded the related litigation. To ensure consistent reconsideration on the same basis and in accordance with law, the existing orders were interfered with and the case sent back to the Commissioner (Appeals) and the Tribunal.

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Issues: Whether the order of the Tribunal and the order of the Commissioner of Income-tax (Appeals) should be set aside and the matter remanded for fresh consideration.

Analysis: The appeal arose from a common factual matrix already considered in connected matters. In view of the subsequent remand by the Supreme Court in the connected litigation and the need for consistent reconsideration on the same factual basis, the existing orders were found fit to be interfered with and the matter sent back for reconsideration in accordance with law.

Conclusion: The Tribunal's order and the order of the Commissioner of Income-tax (Appeals) were set aside and the matter was remanded to the Commissioner of Income-tax (Appeals) and the Tribunal for fresh consideration.

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