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Issues Involved: The judgment involves the consideration of multiple questions raised by the Revenue in appeals related to income tax assessments.
First Issue - Treatment of Interest on Unproved Loans: The main issue in both appeals was whether the Income-tax Appellate Tribunal was correct in directing the Assessing Officer to add interest on the peak credit of unproved loans instead of the entire interest amount. The High Court decided to remand both appeals back to the Tribunal for fresh consideration of this question due to its interconnectivity with other related appeals. Second Issue - Undisclosed Transactions in Block Assessment: The Revenue raised other questions regarding transactions that were disclosed in regular assessments but were being considered for block assessment. The High Court determined that these transactions did not fall under section 158B of the Income-tax Act as they were already disclosed in regular assessments. The Court affirmed the Tribunal's findings on these transactions and partially allowed the appeals, remanding them back to the Tribunal for further consideration only on the first issue. In conclusion, the High Court remanded both appeals to the Tribunal for reevaluation of the treatment of interest on unproved loans, while affirming the Tribunal's findings on disclosed transactions for regular assessment.
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