The appeal is partly allowed and the substantial questions of

Bench: : The Hon’Ble The Chief Justice T.S. Sivagnanam & The Hon’Ble Justice Chaitali Chatterjee (Das) Dated : 7Th March, 2025. Appearance:

Section 260A of the Income Tax Act, 1961 (the Act) is directed against the order dated 29th August, 2024 passed by the Income Tax Appellate Tribunal, “B” Bench, Kolkata in ITA No.51/Kol/2011, for the assessment year 2015-16. The Revenue has raised the following substantial questions of law for consideration: “(i) Whether on the facts and in the circumstances