2014 (6) TMI 150

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... aises no substantial question of law. It is rather disturbing and now established trend that whenever the Revenue files an appeal in relation to certain assessment year/s, in the memo of appeal filed before this court there is no explanation given as to why the assessment year/s in relation to which the Revenue has approached this court is chosen for filing the appeal. We have noted in the cases .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... en the Revenue cannot file an appeal when it accepts the view in relation to the preceding assessment years and pertaining to the very assessee. It is only when the Tribunal's orders are based on law or on erroneous understanding or application thereof, that the hon'ble Supreme Court holds that the Revenue cannot be estopped from questioning the order of the Tribunal even though it has fai .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... d any appeal to this court in relation to the very assessee to challenge the Tribunal's earlier order or orders of prior assessment year and the reason for not filing the same. There should be a statement as to whether the Tribunal's order on facts has been accepted by the assessee or the Revenue. This order has to be passed because very often we find that such non-disclosure is fatal. Thi .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X