2002 (11) TMI 9

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..... s a question of law - language of section 22 and section 139, sub-sections (3) and (4) of the Act do not prima facie appear to be pari materia and it cannot be said that the question raised by the Revenue is not an arguable one. - Civil Appeal No 2004 of 2000 - - - Dated:- 12-11-2002 - Mrs. Ruma Pal And B. N. Srikrishna JJ. For the Appellant : B. B. Ahuja, Senior Advocate (Ranbir Chandr .....

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..... attention to the fact that the decision in Pratapgarh Cold Storage [1982] UPTC 129 1S proceeded on the basis of this court in CIT v. Kulu Valley Transport Co. P. Ltd. [1970] 77 ITR 518. It appears that the decision in Kulu Valley Transport [1970] 77 ITR 518 (SC) was based upon an interpretation of the provisions of section 22 of the Indian Income-tax Act, 1922. The language of section 22 and .....

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