Interim tribunal observations not conclusive on merits; parties' rights remain open for independent determination.

Interim observations in an Income Tax Appellate Tribunal order were held not to be conclusive on the merits. The parties' rights and contentions were left open to be raised before the Tribunal, and the Tribunal was directed to decide the dispute independently and without being influenced by those observations. The effect is that the interim remarks do not preclude a full merits determination in the pending proceedings.

---

---

Issues: Whether the interim observations in the Income Tax Appellate Tribunal's order should be treated as conclusive on the merits, and whether the parties' rights and contentions should remain open before the Tribunal.

Outcome: The observations in the impugned interim orders were directed not to be treated as conclusive on the merits, and all rights and contentions of the parties were left open to be urged before the Tribunal, which was to decide the merits uninfluenced by those observations.

---