Bombay High Court
Pr Commissioner Of Income Tax Central 4 vs Aurum Ventures Private Limited on 17 July, 2026
Author: G. S. Kulkarni
Bench: G. S. Kulkarni
CNR No : HCBM020028082024
24-ITXA-663-24 & ANR.DOC
JYOTI IN THE HIGH COURT OF JUDICATURE AT BOMBAY
RAJESH
MANE ORDINARY ORIGINAL CIVIL JURISDICTION
Digitally signed by
JYOTI RAJESH MANE
Date: 2026.07.23
15:22:36 +0530 INCOME TAX APPEAL NO.663 OF 2024
WITH
INCOME TAX APPEAL NO. 735 OF 2024
Pr.Commissioner Of Income
Tax Central 4 ...Appellant
Versus
Aurum Ventures Private
Limited ...Respondents
_______
Mr. Suresh Kumar, for Appellant.
Mr. P.C.Tripathi, for Respondents.
_______
CORAM: G. S. KULKARNI &
AARTI SATHE, JJ.
DATE: 17 JULY 2026
P.C.
1. These two appeals are filed by the Revenue challenging the common
order dated 20 June 2023 passed by the Income Tax Appellate Tribunal, Mumbai
Bench, whereby the appeals preferred by the Revenue against the orders dated 30
August 2021 passed by the Commissioner of Income Tax (Appeals) [CIT(A)] came
to be dismissed.
2. The assessment years involved are Assessment Year 2015-16 and
Assessment Year 2016-17.
3. The substantial questions of law proposed in both the appeals are common,
the only distinction being the figures involved for the respective assessment years.
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For the sake of convenience, we refer to the questions of law as framed in Income
Tax Appeal No. 663 of 2024, which read thus:
QUESTIONS OF LAW
i. Whether on the facts and circumstances of the case and in law, the tribunal has
erred in considering the certain incriminating documents have been found and
seized during the search proceedings viz. (I) copy of Resolution of Board of
Directors held on 26.11.2013 (A-3 to panchnama dated 25.03.2018 page No.44
to 46), (ii) Escrow Account Agreement dated 03.12.2013 (A-3 to panchnama
dated 25.03.2018 page No.52 to 57), (iii) copy of undertaking given by Aurum
Platz Prt. Ltd. to IFCI Ltd. on 03.12.2013 with respect to sale of duplex
apartment at “Aurum Platz” (A-3 to panchnama dated 25.03.2018 page No.7l to
72), (iv) Correspondence of Aurum Venture Pvt. Ltd. with IFCI Ltd. regarding
concluded negotiation for the sale of apartment No.6 (A-3 to panchnama dated
25.03.2018 page No.l52) and (v) Correspondence between holding company,
Aurum Ventures Pvt. Ltd. and Shri Prasoon, CGM, IFCI regarding the Aurum
loan facility of Rs. 1 15 Crores, wherein it was clearly mentioned at para 4 that
the repayment of the loan and interest thereon was to be paid from the income
and sale of flats of the “Aurum Platz” Building (A-3 to panchnama
dated25.03.2018 page No.169 to 170), these documents unearthed during the
search proceedings, which clearly establish the fact that the intention of the
assessee was to sale flats and the intention of the assessee to carry out business
and not renting or leasing of flats, as part of the regular records maintained by the
assessee.
ii. Whether on the facts and circumstances of the case and in law, the tribunal has
failed to appreciate the fact unearthed from the documents seized during the
search proceedings, led to establishing the fact that the income offered by the
assessee under the head i.e. capital gain was with variance from the right head of
income i.e. Income from Business and Profession. Thereby, the tribunal has not
justified in treating the seized documents as non-incriminating.
Iii. Whether on the facts and circumstances of the case and in law, the tribunal
has erred in considering that treatment of income received from sale of
apartments as business income of the assessee was made by the AO based on the
regular books of accounts maintained by the assessee and details called for during
the course of assessment proceedings u/s 153A of the Act, as there was no
reference of any incriminating material found during the course of search in the
assessment order.
iv. Whether on the facts and circumstances of the case and in law, the tribunal has
erred in deleting addition made u/s.36(l)(iii) of Act, without considering the facts
of the case that on similar grounds in the assessee’s own case, the Ld.CIT(A) has
confirmed the addition made u/s.36(l)(iii) of the Act, in the order u/s 153A r.w.s.
143(3) dated 30.l2.20l9 for A.Y. 2017- 18 and in the order u/s 143(3) dated
30.12.2019 for A.Y. 2018-19 and the assessee has accepted the decision of the
CIT(A), confirming the disallowance made u/s.36(1)(iii) of the Act.
v. On the facts and circumstances of the case and in law, the tribunal, has erred in
deleting the disallowance u/s 36(l)(iii) of the Act without considering the
detailed findings of the Assessing Officer that the investments made by the
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assessee are capital in nature and emanating from information unearthed by the
investigation wing during the course of search on Aurum Group which are
incriminating in nature.
4. At the outset Mr. Suresh Kumar learned counsel for the Appellants
would fairly submit that in the interim period the position in law and insofar as the
materials which may be recovered in the search and seizure only in the event they
are incriminating could be taken into consideration is the settled position in law. In
this context reliance is placed on the decision of the Supreme Court in Principal
Commissioner of Income Tax Central-3 Vs. Abhisar Buildwell (P) Ltd.1
5. Our attention is drawn to an order dated 13 March 2026 passed by this
Bench on Income Tax Appeal No. 996 of 2024,The Principal Commissioner of
Income Tax Central-4 Vs. Maneesh Pharmaceuticals Ltd. in which this Court in
similar context had made the following observations referred to this decision :
1. These appeals under Section 260A of the Income Tax Act, 1961 (`the Act’) filed
by Revenue challenge an order dated 25th October 2021 passed by the Income Tax
Appellate Tribunal (Tribunal) whereby the appeals filed by the Department are rejected
confirming the orders passed by the Commissioner of Income Tax (Appeals) [CIT-(A)].
Assessment Year in question in Appeal No.939 of 2019 is A.Y.2006-07. Insofar as
Appeal No.996 of 2024 and Appeal No.122 of 2025 are concerned, the assessment
years in question are A.Y.2007-08, 2008-09 and 2009-10 for which a common order
dated 25th October 2021 has been passed by the Tribunal. Learned Counsel on behalf
of the Appellant-Revenue contends that the only difference in these appeals is that in
some assessment years, the assessment orders are passed under Section 143(1) of the Act
and in some years the assessment orders are passed under Section 143(3) of the Act.
However the issue and questions of law remain the same. Illustratively, as the questions
of law, as raised on behalf of Revenue are common, we quote the questions of law in the
lead Appeal No.939 of 2019, which reads thus :
“QUESTION OF LAW
i. Whether on the facts and in the circumstances of the case and in law, the
Hon’ble ITAT was justified in directing the AO to delete the additions which
were made by the AO on account of ALP adjustment of Rs. 19,53,522l-,
deduction u/s. 10B of Rs. 10,69,98,599/- and exceptional items written off of
Rs. 33,27,68,000/-, relying on the decision of Bombay High Court in the case
of All Cargo Logistics Ltd(374 ITR 645) without appreciating the fact that the
case for A.Y. 2008-09 was never selected for scrutiny for regular assessment u/s
143(3) of the I.T. Act and therefore the question of its abatement never arose.
1 (2023)149 TAXMANN.COM 399(SC)
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24-ITXA-663-24 & ANR.DOCii. Whether on the facts and in the circumstances of the case and in law, the
Hon’ble ITAT was justified in directing the AO to delete the additions which
were made by the AO on account of ALP adjustment of Rs. 19,53,522/-,
deduction u/s. 10B of Rs. 10,69,98,599/- and exceptional items written off of
Rs. 33,27,68,000/-, relying on the decision of Bombay High Court in the case
of All Cargo Logistics Ltd(374 ITR 645) without appreciating the fact that the
decision of the High Court has not been accepted by the department and SLP
has been filed and the same is pending.”
2. The Respondent-assessee filed its return of income for the Assessment years in
question declaring its income, as set out in the respective proceedings. A search action
under Section 132 of the Act was conducted in the case of the assessee on 29 th August
2011, consequent to which a notice under Section 153A was issued to the assessee and
thereafter the Assessing Officer completed the assessment proceedings under Section
153A read with Section 143(3) of the Act assessing the income of the assessee.
3. Aggrieved by such order passed by the Assessing Officer, the assessee has filed an
appeal before the Commissioner of Income Tax (Appeals) [CIT(A) for short]. The
CIT(A) passed an order dated 21st May 2018 partly allowing the appeal of the assessee
whereby the additions which were made by the Assessing Officer were deleted on
account of ALP adjustments and disallowance of other items while observing that the
additions were not based on any incriminating material found from the search relying
on the decision of the Tribunal in the case of All Cargo Global Logistics Limited Vs
Deputy Commissioner of Income Tax, Central Circle-44 2, and also the decision of this
Court in the case of CIT Vs. Continental Warehousing Corporation 3. The Department
being aggrieved by the orders passed by the CIT(A) approached the Tribunal in which
the impugned orders have been passed. On such backdrop the present appeals are filed.
4. At the outset Mr.Suresh Kumar, learned counsel for Revenue, would not dispute
that no incriminating material was found from the search under Section 132 of the Act
against assessee. He also fairly submitted that the position in law in such circumstances
when the assessment under Section 143(3) itself has attained finality, is well settled. We
may observe that the Tribunal disposing of the Revenue’s appeals made the following
observations :
“5. We have heard both the parties and perused the records. It is not disputed
by the revenue that on the aforesaid items of addition, no incriminating
material was found during search. Assessment order under section 143(3) was
already passed for assessment year 2007-08 prior to the search and notice. The
period for issuing notice under section 143(2) was also over for assessment year
2008-09 and 2009-10 by the time of search and notice. In such circumstances it
is evident that these are not abated assessments. In such circumstances the
decision of honourable Bombay High Court in the case of All Cargo Global
Logistics Ltd. (supra) and Continental Warehousing Ltd. (supra) clearly
mandate that the addition cannot be done under section 153A without any
incrementing material found during search. The Revenue submits in grounds of
appeal that they have not accepted the Hon’ble Bombay High Court decision
and SLP has been filed before Hon’ble Supreme Court. This is no reason for us
to not follow Hon’ble Jurisdictional High Court exposition. Hence in our
considered opinion there is no infirmity in the order of learned CIT(appeals).”
5. We find that there are consistent line of decisions on the issues which were
canvassed by the assessee before the forums below. In Commissioner of Income Tax,
2[2012] 33 CCH 0294 (Mum) (SB)
3(374 ITR 645)
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Central-II, Mumbai Vs. Gurinder Singh Bawa 4, a co-ordinate Bench of this Court of
which one of us (G.S.Kulkarni, J.) was a member, in similar situation, categorically held
that once the assessment has attained finality for a particular year i.e. it is not pending,
then it cannot be subject to tax in proceedings under Section 153A of the Act. Such
decision was also accepted by the Department. The relevant extract of the said decision
is required to be noted, which reads thus :
“6. Mr.Kotangale, the learned counsel for the Revenue very fairly states that the
decision of the Special Bench of the Tribunal in A1-Cargo Global Logistics Ltd was a
subject matter of challenge before this Court as a part of the group of appeals disposed
of as CIT V. Continental Warehousing Corporation (Nhava Sheva) Ltd. (2015)374
ITR 645/58 taxmann.com 78/232 Taxman 270 (Bom) upholding the view of the
Special Bench of the Tribunal in A1-Cargo Global Logistics Ltd. Consequently, once
an assessment has attained finality for a particular year i.e. it is not pending then the
same cannot be subject to tax in proceedings under Section 153A of the Act. This of
course would not apply if incriminating materials are gathered in the course of search or
during proceedings under Section 153A of the Act which are contrary to and/or not
disclosed during regular assessment proceedings.
7. In view of the above, on issue of jurisdiction itself the issue stands concluded against
the revenue by the decision of this Court in Continental Warehousing Corpn. (Nhava
Sheva) Ltd. (supra). In the appeal before us, the revenue has made no grievance with
regard to the impugned order of the Tribunal holding that in law the proceedings
under Section 153A of the Act are without jurisdiction. This in view of the fact that no
assessment were pending, so as to abate nor any incriminating evidence was found.
The grievance of the revenue is only with regard to finding in the impugned order on
the merits of the individual claim regarding gifts and deemed dividend. However once
it is not disputed by the revenue that the decision of this Court in Continental
Warehousing Corporation (Nhava Sheva) Ltd. (supra) would apply to the present facts
and also that there are no assessments pending on the time of the initiation of
proceedings under Section 153A of the Act. The occasion to consider the issues raised
on merits in the proposed questions becomes academic.”
6. Similar view is also taken in the case of Commissioner of Income Tax Vs. SKS
Ispat & Power Limited5, in which also reference to the decision in the case of CIT Vs
Gurinder Singh Bawa (supra) is made. The relevant extract of which reads thus :
“4. Even in the case of CIT Vs. Gurinder Singh Bawa (2017) 79 taxmann.com 398
(2016) 386 ITR 483 (Bom) decided by this Court, the assessment was under section
143(1) of the Act. The learned advocate relied on the judgment of this court in
Gurinder Singh Bawa (supra) and another judgment of this Court in the case of CIT Vs.
Continental Warehousing Corpn. (Nhava Sheva) Ltd. (2015) 58 taxmann.com 78/232
Taxman 270/374 ITR 645 (Bom).
5. We have considered the arguments canvassed by the learned counsel for the
respective parties. On perusal of section 153A of the Act, it is manifest that it does not
make any distinction between assessment conducted under section 143(1) and 143(3).
This court had occasion to consider the scope of section 153A of the Act in the case of
Gurinder Singh Bawa and in the case of Continental Warehousing Corpn. (Nhava
Sheva) Ltd. (referred to supra). It has been observed that section 153A cannot be a tool
to have a second inning of assessment either to the Revenue or the assessee. Even in the
case of Gurinder Singh Bawa (referred to supra) the assessment was under Section
143(1) of the Act and the court held that the scope of assessment after search under
Section 153A would be limited to the incriminating evidence found during the search
and no further. In the said judgment, the judgment of this Court in Continental
Warehousing Corpn. (Nhava Sheva) Ltd (referred to supra) has been followed.”
4(2017)79-taxmann.com-398
5(2018)99-taxmann.com-424
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7. This apart, the position stands well settled under a recent decision of Supreme
Court in the case of Principal Commissioner of Income Tax, Central-3 Vs. Abhisar
Buildwell (P) Ltd6 in which the Supreme Court laid down the following clear position
in law :
“14. In view of the above and for the reasons stated above, it is concluded as under:
(i) that in case of search under section 132 or requisition under section 132A, the AO
assumes the jurisdiction for block assessment under Section 153A;
(ii) all pending assessments/reassessments shall stand abated;
(iii) in case any incriminating material is found/unearthed, even, in case of
unabated/completed assessments, the AO would assume the jurisdiction to assess or
reassess the `total income’ taking into consideration the incriminating material
unearthed during the search and the other material available with the AO including the
income declared in the returns; and
(iv) in case no incriminating material is unearthed during the search, the AO cannot
assess or reassess taking into consideration the other material in respect of completed
assessments/unabated assessments. Meaning thereby, in respect of completed/unabated
assessments, no addition can be made by the AO in absence of any incriminating
material found during the course of search under section 132 or requisition under
section 132A of the Act, 1961. However, the completed/ unabated assessments can be
re-opened by the AO in exercise of powers under sections 147/148 of the Act, subject
to fulfilment of the conditions as envisaged/ mentioned under sections 147/148 of the
Act and those powers are saved.
The question involved in the present set of appeals and review petition is answered
accordingly in terms of the above and the appeals and review petition preferred by the
Revenue are hereby dismissed. No costs.”
8. We may also refer to a decision of this Court on a batch of petitions in Principal
Commissioner of Income Tax, Central-1 Vs. Speciality Paper Limited 7, in which in
similar circumstances also referring to the decision of this Court in CIT Vs.
Continental Warehousing Corporation (Nhava Sheva) Ltd. (supra) as also decision
of Supreme Court in Principal Commissioner of Income-tax, Central-3 Vs. Abhisar
Buildwell (P.) Ltd.(supra), the Court made the following observations:
v”2. Before the Tribunal, disputes had arisen from the order passed by the
Commissioner of Income Tax (Appeal) taking a view that in the absence of any
incriminating material found in the course of search, no additions are permissible in
the assessments made under Section 153 (C) of the Act in years, where the original
assessments do not abate, following the decision of this Court in Commissioner of
Income Tax vs. Continental Warehousing Corporation (Nhava Sheva) Ltd. 8.
3. In Commissioner of Income Tax vs. Continental Warehousing Corporation
(supra), before this Court, an issue which had fell for consideration of this Court, was
‘whether in a case where pursuant to issuance of a notice under Section 153A
assessments are abated, Assessing Officer retains original jurisdiction as well as
jurisdiction conferred on him under Section 153A, for which assessments be made for
each of six assessment years separately’. This Court, considering the relevant
provisions, held that no addition can be made in respect of unabated assessments6(2023) 149 taxmann.com 399 (SC)
7Income Tax Appeal No.16 of 2019 and batch, decided on 14-8-2024
8374 ITR 645 (Bom.)Page 6 of 10
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24-ITXA-663-24 & ANR.DOCwhich have become final, if no incriminating material was found during search. The
relevant observations as made by the Court are required to be noted which read thus: –
“29. We are not in agreement with Mr. Pinto that these observations are
made in passing or that they are not binding on us because the essential
controversy before the Bench was somewhat different. He urges that was only
in relation to the legality and validity of the order of the Commissioner under
section 263 of the IT Act. Had that been the case, the Division Bench was
not required to trace out the history of section 153A of the IT Act and the
power that is conferred thereunder. When the Revenue argued before the
Division Bench that the power under section 153A can be invoked and
exercised even in cases where the second proviso to sub-section (1) is not
applicable that the Division Bench was required to express a specific opinion.
The provision deals with those cases where assessment or reassessment, if any,
relating to the assessment years falling within the period of six assessment
years referred to in sub-section (1) of section 153A were pending. If they
were pending on the date of the initiation of the search under section 132 or
making of requisition under section 132A, as the case may be, they abate. It is
only pending proceedings that would abate and not where there are orders
made of assessment or reassessment and which are in force on the date of
initiation of the search or making of the requisition. As that specific argument
was canvassed and dealt with by the Division Bench and that is how it was
called upon to interpret section 153A of the IT Act, then, each of the above
conclusions rendered by the Division Bench would bind us.
30. Even otherwise, we agree with the Division Bench when it observes
as above with regard to the ambit and scope of the powers conferred under
section 153A of the Act. Since we are not required to trace out the history
and we can do nothing better than to reproduce the observations and
conclusions as above that we are not repeating the same. Even if the exercise
of power under section 153A is permissible still the provision cannot be read
in the manner suggested by Mr. Pinto. Not only the finalised assessment
cannot be touched by resorting to those provisions, but even while exercising
the power can be exercised where a search is initiated under section 132 or
books of account, other documents or any assets are requisitioned under
section 132A after 31st March, 2003. There is a mandate to issue notices
under section 153(1)(a) and assess or reassess the total income of six
assessment years immediately preceding the assessment year relevant to the
previous year in which such search is conducted or requisition is made. Thus,
the crucial words “search” and “requisition” appear in the substantive
provision and the provisos. That would throw light on the issue of
applicability of the provision. It being enacted to a search or requisition that
its construction would have to be accordingly. That is the conclusion reached
by the Division Bench in Murli Agro (supra) with which we respectfully
agree. These are the conclusions which can be reached and upon reading of
the legal provisions in question.”
6. Mr. Suresh Kumar, learned counsel for the Revenue has drawn our attention to the
decision of the Supreme Court in Principal Commissioner of Income-tax, Central-3 Vs.
Abhisar Buildwell (P.) Ltd.9 to submit that the issue involving interpretation of the
provisions of Section 153A read with Sections 132 and 143 had fell for consideration of
the Supreme Court, which had arisen from the decision of this Court as also from the
decisions of the other High Courts. The Supreme Court held that in respect of completed
assessments/ unabated assessments, no addition can be made by Assessing Officer in
absence of any incriminating material found during course of search under Section 132 or
requisition under Section 132A. It is also, however, held that completed/ unabated
assessments can be reopened by Assessing Officer in exercise of powers under Section
9 [2023] 149 taxmann.com 399(SC)
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147/148 subject to fulfillment of conditions as envisaged under Section 147/148 and those
powers were saved.
7. Thus, the view of this Court in Commissioner of Income Tax vs. Continental
Warehousing Corporation (supra) has found approval of the Supreme Court. In view of
the authoritative pronouncement of the Supreme Court in Principal Commissioner of
Income-tax, Central-3 Vs. Abhisar Buildwell (P.) Ltd. (supra), the question of law as raised
by the revenue would not arise for consideration. However, it is clarified that the
completed/unabated assessments can be reopened by the Assessing Officer in exercise of
powers under Section 147/148 of the Act subject to fulfillment of conditions as envisaged
under the said provisions and as may be permissible in law. All contentions of the parties
in that regard are expressly kept open.
9. The aforesaid discussion would clearly indicate that the position in law now
stands well settled as followed by the Tribunal. Hence, no error whatsoever, muchless
any illegality can be attributed to the orders passed by the Tribunal as impugned. The
question of law stands clearly covered by the decisions as noted hereinabove. The
appeals accordingly are required to be rejected. They are accordingly rejected. No
costs.
10. Interim Application No.41715 of 2025 does not survive and stands disposed of.
6. Applying the aforesaid principles to the facts of the present case, we
find that, as observed by the Tribunal in the impugned order, a search and seizure
action under Section 132(1) of the Income Tax Act was carried out on 22 March
2018 by the DDIT (Investigation), Unit-6(1), Mumbai, in the case of the Aurum
Group and its related entities. Consequent thereto, notices under Section 153A of
the Act came to be issued.
7. Upon a consideration of the material on record, the Tribunal has
categorically held that no incriminating material was found during the course of
the search in relation to the additions and disallowances made by the Assessing
Officer. The Tribunal’s findings in that regard are based on the record. The relevant
observations of the Tribunal need to be noted which read thus:
17. We have perused the material on record, the orders passed by the lower
authorities and have given our thoughtful consideration to the contentions
placed by the Ld. DR and Ld. AR. The crux of the matter under appeal which
needs adjudication is whether addition or disallowance can be made during
the course of assessment proceedings u/s 153A if no incriminating material orPage 8 of 10
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addition and disallowance. It is a settled position in law that completed
assessments can be interfered with by the AO while making the assessment
under Section 153A only on the basis of some incriminating material
unearthed during the course of search or requisition of documents or
undisclosed income or property discovered in the course of search which were
not produced or not already disclosed or made known in the course of original
assessment. Thus, it is sufficiently clear that the additions made during the
course of assessment proceedings u/s 153A can only be made on the basis of
incriminating material found and seized during the course of search and the
earlier proceeding which has attained finality cannot be disturbed.
18. In the present case, the assessment proceeding for the year under
consideration, was completed vide order dated 23.12.2017 u/s 143(3) of the
Act i.e. before the date on which search was conducted. The addition made by
the AO by treating the proceeds from sale of flats as income under the
head’Profits and Gains from Business and Profession’ and disallowance of
interest expenditure u/s 36( l)(iii) was not based on any ‘incriminating
material’ seized during the course of search proceedings. This is evident from
the fact that there is absolutely no reference of any incriminating material by
the Assessing Officer in his assessment order. The documents relied upon by
the AO were part of regular books of accounts maintained by the assessee and
did not pertain to any undisclosed income earned by the assessee company
8. In the light of the aforesaid discussion, we are of the clear opinion that
no substantial question of law arises for consideration on the issue urged on behalf
of the Revenue.
9. Insofar as the other issue, namely, the disallowance of interest expenditure
under Section 36(1)(iii) of the Income Tax Act, is concerned, the same is also not
founded on any incriminating material seized during the course of the search
proceedings. We are in complete agreement with the view taken by the Tribunal,
which is in consonance with the law laid down by the Courts and the settled legal
position as noticed by us hereinabove. In that view of the matter as well, no
substantial question of law arises for consideration in the present appeal.
10. Insofar as the companion appeal is concerned, it arises out of the very
order passed by the Tribunal. Since the issues involved are identical, separate
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reasons are not required to be recorded while adjudicating the said appeal. It is
being dismissed on the aforesaid reasons.
11. The appeals are accordingly dismissed. No costs.
(AARTI SATHE, J.) (G. S. KULKARNI, J.)
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