COMMISSIONER OF INCOME TAX Vs. SUNIL J KINARIWALA

JUDGEMENT

(1.) This appeal, by the Revenue, is directed against the judgment of the Division Bench of the High Court of Gujarat in Income-tax Reference No. 191 of 1980 dated 29th October, 1993 (Sunil J. Kinariwala v. Commissioner of Income-tax, reported in (1995) 211 ITR 127)).

(2.) At the instance of the Revenue, the Income-tax Appellate Tribunal (for short, 'the Tribunal') referred the following questions, under Section 256(1) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'), for the opinion of the High Court :

(3.) The facts which gave rise to these questions may be noticed here.