1987 (1) TMI 57

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..... first question seeks to challenge the applicability of section 147(a) of the Income-tax Act, 1961. This, in our opinion, is a finding of fact, as the Tribunal has found that the assessee has not disclosed fully and truly all the facts necessary for the assessment for the assessment year 1971-72 at the time of the original assessment. The second question raised by the assessee involves two points ( .....

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..... question of law. We, therefore, direct the Tribunal to state a case and refer the following question of law for the decision of this court : " Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal acted within its jurisdiction in directing the Income-tax Officer to allow the assessee a deduction of Rs. 1,00,000 under section 80G for the assessment year 1972 .....

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