2011 (2) TMI 1349

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....TICE AKIL KURESHI) Revenue is in Appeal, seeking reference of following substantial questions of law :- [A] "Whether the Appellate Tribunal is right in law and on facts in reversing the order passed by the CIT [Appeals] and thereby deleting the job charges of ₹ 9,68,627/= made under Section 40A(2)(b)? [B] Whether the Appellate Tribunal is right in law and on facts in reversing the order p....

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.... CIT [A], from which appeal over the Tribunal arose to contend that the CIT [A] held those issues in favour of the Revenue. On the other hand, counsel for the assessee submitted that the issue in both the years arises out of the identical facts. In fact, in the year under consideration, in the present appeal, the assessee had claimed limited benefit as compared to the previous year. Upon perusal ....