The Commissioner Of Income Tax, Central – I, Mumbai v. M/S.wockhardt Life Sciences Limited, Mumbai

IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL (L) NO.2632 OF 2008ANDINCOME TAX APPEAL (L) NO.2633 OF 2008ANDINCOME TAX APPEAL (L) NO.2634 OF 2008 The Commissioner of Income Tax, Central – I, MumbaiVersusM/s.Wockhardt Life Sciences Limited, Mumbai ..Appellant. ..Respondent. Mr.P.S. Sahadevan for the appellant. Mr.A.K. Jasani for the respondent. CORAM : V.C. DAGA &J.P. DEVADHAR, JJ. DATE : 2[nd] July, 2009 P.C. : 1.Heard learned counsel for the revenue. 2.The question of law sought to be raised in these appeals revolve around non-compliance of conditions stipulated under Section 147 of the Income Tax Act, 1961. The Tribunal has categorically recorded finding of fact based on appreciation of evidence, which reads as under : “6............ In our opinion, if any deduction is allowed after considering the material facts and the relevant provisions then it cannot be said that any income had escaped on account of failure on the part of the assessee to disclose fully and truly the material facts. In view of the above discussion, the orders of the CIT (A) are upheld. 3.In the above view of the matter, no substantial question of law is involved in these appeals. The appeals are, therefore, dismissed with no order as to costs.