1995 (2) TMI 25

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..... ncome-tax Act, 1961, the Commissioner of Income-tax has prayed to direct the Tribunal to refer the following question of law for the opinion of this court : " Whether, on the facts and in the circumstances of the case and in law, the Tribunal was correct in holding that the document marked as annexure-C-23 did not belong to the assessee-firm and, consequently, deleting the addition of Rs, 48,378 .....

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..... 378 and Rs. 41,000. We have gone through the order of the Income-tax Appellate Tribunal and also the provisions of section 132(4A) and also the document annexure-C-23, In our opinion, prima facie, the finding of the Tribunal regarding ownership and construction of the document gives rise to the aforesaid question of law. Consequently, we direct the Income-tax Appellate Tribunal to refer the af .....

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