ORDER 1. Special leave granted. 2. We have heard counsel for the parties. 3. The impugned judgment of the High Court has to be set aside on the simple ground that the High Court did not frame the substantial questions of law which arose for consideration in the appeal as required by Section 260-A of the Income Tax Act (hereinafter referred to as "the Act") . 4. We, therefore, set aside the impugned judgment of the High Court and remit the matter to the High Court to proceed in accordance with law, after framing the questions as required by Section 260-A of the Act. 5. The appeals are allowed. 6. No orders as to costs.