2020 (12) TMI 826

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.... ORDER PER : HONOURABLE MR. JUSTICE J.B.PARDIWALA 1. This appeal under Section 260A of the Income Tax Act, 1961 (for short "the Act, 1961") is at the instance of the Revenue and is directed against the order passed by the Income Tax Appellate Tribunal, Rajkot Bench, Rajkot dated 27th November, 2019 in the ITA No. 125/RJT/2015 for the A.Y. 2006-07. The Revenue has proposed the following th....

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....immediately preceding the assessment year relevant to the previous year in which the search was initiated? (3) Whether the Appellate Tribunal has erred in law and on facts in not considering the scope of the term "total income" as defined in section 2(45) read with section 5 of the Act while holding that no addition/disallowance can be made on issues other than those based on documents or....

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....Appeal fails and is hereby dismissed. 5. At this stage Mr. Bhatt, the learned Senior Counsel appearing for the Revenue invited our attention to certain observation made by the Appellate Tribunal in para-11 of the impugned judgment. In para-11, the Tribunal has observed that as such, there is no differentiation found in the intent of the Legislature to discriminate whether the assessments were o....