M.R.SHAH, B.N.KARIA
Principal Commissioner of Income Tax – Appellant
Versus
Devangi – Respondent
M.R. Shah, J.
1. As common question of law and facts arise in this group of appeals, they are disposed of by this common judgment and order.
2. Feeling aggrieved and dissatisfied with the impugned common judgment and order passed by the learned Income Tax Appellate Tribunal "C" Bench, Ahmedabad, passed in IT (SS) A Nos. 138 to 141/AHD/2011 for AY 2001-02 to 2004-05, by which, the learned Tribunal has allowed the said appeals and has directed to AO to delete the addition made under Section 153 A of the Act for AY 2000-01 to 2004-05, the Revenue has preferred present Appeals with the following proposed questions of law.
"A. Whether on the facts and in the circumstances of the case, the Appellate Tribunal is correct in narrowing down the scope of assessment u/s. 153 A in respect of completed assessments by holding that only undisclosed income and undisclosed assets detected during the search could be brought to tax?
B. Whether on the facts and in the circumstances of the case, the Appellate Tribunal is correct in law in holding that the scope of Section 153 A is limited to assessing only search related income, thereby denying Revenue the opportunity of taxing other escaped incom
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