2004 (6) TMI 21

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....ent) under section 260A of the Income-tax Act, 1961, against an order, dated November 21, 2003, passed by the Income-tax Appellate Tribunal in I.T. (SS A. No. 6/Ind of 2002). In short, the question that arises for consideration in this appeal is, whether this appeal involves any substantial question of law as is required to be made out under section 260A of the Act that being the pre-requisite fo....

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....is total income. The Commissioner of Income-tax (Appeals) as also the Tribunal set aside the order of the Assessing Officer in so far as it related to additions made by him (AO). In other words, the Commissioner of Income-tax (Appeals) and the Tribunal accepted the factual explanation coupled with the evidence tendered by the assessee in relation to the impugned additions, made by the Assessing Of....

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.... find out whether explanation offered by the assessee and which found acceptance to two appellate authorities, namely, the Commissioner of Income-tax (Appeals) and the Tribunal, is good or bad, or whether it was rightly accepted, or not. It is only when the factual finding is entirely de hors the subject, or that it is based on no reasoning, or that it is absurd to the extent that no reasonable pr....