Appeals Dismissed by High Court Based on Precedents and Filing Discrepancy

The High Court dismissed the appeals against the Income-tax Appellate Tribunal's order for various assessment years. The Court relied on its own judgments and a Supreme Court decision, dismissing the appeals based on established precedents. The Revenue's incorrect averment regarding a challenge to another case led to the dismissal of the appeal due to the discrepancy in the timeline of filings.

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Issues:
Appeal against Income-tax Appellate Tribunal's order for multiple assessment years. Reliance on earlier Tribunal orders. Challenge to the decision based on Supreme Court and High Court judgments. Formulation of substantial question of law. Incorrect averment by Revenue regarding challenge to another case.

Analysis:
The judgment pertains to appeals against an order of the Income-tax Appellate Tribunal for various assessment years. The Tribunal's decision was based on its earlier orders concerning different entities. These primary orders were accepted by the Revenue and not challenged through an appeal. The High Court, following the Supreme Court's decision in Union of India v. Satish Panalal Shah and its own judgment in CIT v. A. R. J. Security Printers, dismissed the appeals. The Court also referred to its reasoning in a related case, CIT v. Moonlight Builders and Developers, for the dismissal.

A substantial question of law was formulated by the Court through an ex parte order. The Revenue had raised an argument in one of the grounds of appeal, contending that the Tribunal's decisions were distinguishable and that the order in the case of Moonlight Builders and Developers Limited was under challenge. However, it was found that the averment made by the Revenue was incorrect. The appeal in question was filed before the appeal related to Moonlight Builders and Developers Limited, leading to the dismissal of the appeal based on this discrepancy.

In conclusion, the High Court dismissed the appeals against the Tribunal's order, citing precedents from the Supreme Court and its own judgments. The Court corrected an incorrect averment made by the Revenue regarding the challenge to another case, leading to the dismissal of the appeal based on this discrepancy.

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