(1.) THE Tribunal has referred the following questions under s. 256(1) of the I.T. Act, 1961 :
(2.) THE facts that we could gather from the statement of the case are these :
(3.) THE Addl. CIT in exercise of his suo moto power under s. 263 of the I.T. Act, 1961, revised the assessment order after affording an opportunity to the assessee. THE Commissioner has observed thus :