(1.) THE Department seeks a reference in respect of the following two questions :
(2.) THE dispute in respect of both the questions relates to the applicability of rule 1BB. THE Tribunal has held that it is a procedural rule and, therefore, it may be given effect to even in respect of pending matters. THEre is no dispute and indeed it cannot be disputed that rule 1BB is procedural in nature. That being the portion, we fail to see any question of law arising out of the order the Tribunal, since it is always not disputed that the rules of procedure can be called into aid in respect of pending matters.