2014 (6) TMI 150

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.... are of the view that the appeal raises no substantial question of law. It is rather disturbing and now established trend that whenever the Revenue files an appeal in relation to certain assessment year/s, in the memo of appeal filed before this court there is no explanation given as to why the assessment year/s in relation to which the Revenue has approached this court is chosen for filing the....

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....s. If the matter is purely factual, then the Revenue cannot file an appeal when it accepts the view in relation to the preceding assessment years and pertaining to the very assessee. It is only when the Tribunal's orders are based on law or on erroneous understanding or application thereof, that the hon'ble Supreme Court holds that the Revenue cannot be estopped from questioning the order ....