9911796707
TMI Blog2014 (10) TMI 587X X X X Extracts X X X X X X X X Extracts X X X X ..... d - A pure factual finding cannot be re-appreciated and reapprised - That finding has been consistently rendered by the Tribunal and for prior assessment years in the case of the very assessee - If the Tribunal follows and applies it on the same facts for a subsequent assessment year, that exercise undertaken by the Tribunal cannot be termed as perverse or vitiated by any error of law, apparent on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pearing on behalf of the revenue submits that this appeal raises a substantial question of law. The income derived by way of interest from security had accrued and in terms of book accounts maintained by the respondent-assessee, which is a banking company. However, that was not offered to tax on accrual basis but on actual receipt. Mr.Chandrapal submits that in relation to a claim under section 43 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng to the same assessee. That has been raised for the assessment years 2000-01, 2001-02 and 2004-05 and the Tribunal has been consistently following its view and in the case of the very assessee and this view has been taken for prior assessment years. In relation to assessment year 2000-01, the Tribunal passed a detailed order in favour of the assessee in Income Tax appeal No.931/M/04. That order ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e of this very assessee for prior assessment year 2000-01. That is how the conclusion in para No.6 of the Tribunal is reached. In such circumstances, we are of the opinion that the only question of law projected as substantial one, cannot be entertained. A pure factual finding cannot be re-appreciated and reapprised. That finding has been consistently rendered by the Tribunal and for prior assessm ..... X X X X Extracts X X X X X X X X Extracts X X X X
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