JUDGMENT

R.K. Agrawal, J.

Leave granted.

2. These appeals have been preferred against the impugned judgment and order dated 23.12.2014 passed by the High Court of Gujarat at Ahmedabad in Tax Appeal Nos. 6 and 14 of 2004 whereby the Division Bench of the High Court dismissed the appeals filed by the Revenue while upholding the decision of the Income Tax Appellant Tribunal (for brevity 'the Tribunal') dated 27.06.2003.

3. Brief facts:-

(a) On 10.09.1998, the Respondent, who is the Chairman and Managing Director of Procter and Gamble (P&G), India, filed his income tax return for the Assessment Year 199899 and declaring the total income at Rs. 40,13,820/-.

(b) The Assessing Officer, vide order dated 12.02.2001, concluded the assessment proceeding under Section 143(3) of the Income Tax Act, 1961 (in short 'the IT Act') and determined the total income of the Respondent at Rs. 7,23,11,013/- against the declared income.

(c) Being aggrieved, the Respondent preferred an appeal before the Commissioner of Income Tax (Appeals) being No. CAB/I-643/2000-2001. After considering the case, learned CIT (Appeals), vide order dated 28.03.2002, dismissed the appeal of the Respondent after comprehensively discu