Moreover, as held in British Bank of India Vs. CIT
[2004] (1) Mh.L.J.297, there is no inherent right of appeal and it
has to be specifically conferred by the statute.
However, more appropriate and direct on the point is the decision of
the Bombay High Court in British Bank of India Vs. Commissioner
Income-Tax [2004] 266 ITR 269 (Bom.), wherein reference was made to
ITA 457/2005 Page 6 of 8Section 246 (1) (f) which was pari materia to the clause applicable and it
was held as under:
In furtherance of their
arguments with respect to the word "all" they had placed reliance on
Jairam Narayan Raje (supra) and All India Indian Overseas Bank SC
and ST Employees' Welfare Association and Others (supra) wherein
the courts had held that in certain situations the word "all" may be
interpreted in a restrictive manner depending on the context and subject in
which the word has been used keeping in mind the object of the provisions
enacted. In the present case one may examine the present provision once
again that reads as follows: