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TMI Blog1988 (7) TMI 52X X X X Extracts X X X X X X X X Extracts X X X X ..... llaneous Civil Case No. 327 of 1982. These are applications under section 256(2) of the Income-tax Act, 1961 (hereinafter referred to as "the Act"). The material facts giving rise to these applications briefly areas follows : As there was a delay by the assessee in filing the returns for the assessment years 1972-73 and 1974-75, the Income-tax Officer initiated penalty proceedings under sectio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... missible to the assessee in the light of the order passed by the Tribunal. Aggrieved by that order, the Revenue sought reference but as the applications made in that behalf were rejected by the Tribunal, the Revenue has filed these applications. Having heard the I earned counsel for the Revenue, we have come to the conclusion that these applications deserve to be rejected. The Tribunal has found ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... following question of law : "Whether the Tribunal has made any operative order in accordance with law relating to the imposition of penalty for the assessment year 1970-71 ?" The question as to whether the Tribunal has made any operative order does not at all arise in the instant case. As already observed, the question sought to be referred in these cases is whether there was any reasonable ca ..... X X X X Extracts X X X X X X X X Extracts X X X X
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