TECHNOVA IMAGING SYSTEMS LTD. vs DEPUTY COMMISSIONER OF INCOME TAX.

403-ITX-405-2003.odt IN THE HIGH COURT OF JUDICATURE AT BOMBAY URMILA ORDINARY ORIGINAL CIVIL JURISDICTION PRAMOD INGALE 1. Deputy Commissioner of Income Tax Sepcial Range – 47, Mumbai having his ofifce at R. No. 645, 6th floor, Aayakar Bhavan, Maharshi Karve Road, Mumbai 400 020. 2. Commissioner of Income Tax City – V, Mumbai having his office at Ayayakar Bhavan Maharshi Karve Road, Mumbai – 400 020 .… Respondents **** Mr. Pankaj Toprani a/w Ms.Krupa Toprani i/b PRH Juris Consults, for the Appellant. Mr.Suresh Kumar, for the Respondent. **** CORAM : ALOK ARADHE, CJ & M.S.KARNIK, J. RESERVED ON : 03rd APRIL, 2025 PRONOUNCED ON : 09th APRIL, 2025 JUDGMENT (PER M.S.KARNIK, J.) : 1. This appeal under Section 260A of the Income Tax Act, 1961 (‘IT Ingale 1 403-ITX-405-2003.odt Act’, for short) is against the order of the Income Tax Appellate Tribunal, (‘the Tribunal’, for short), Mumbai Bench, ‘D’ Mumbai dated 10/01/2003. The appeal was admitted on 19/10/2004 on the following substantial question of law : “Whether on the facts and in the circumstances of the case, the Tribunal was justified in law in holding that in view of insertion of section 72A in the Income-tax Act, 1961, the appel