SURAM CHAND REHLAN Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) THE petitioner had sought reference of the following questions of law under S. 256(1) of the IT Act, 1961 ;

(2.) IN our opinion, the aforesaid questions are not questions of law. As far as questions Nos. 1 and 2 are concerned, there is material on record on the basis of which the Tribunal has come to its conclusion and the said questions are pure questions of fact.

(3.) AS regards question No. 4 is concerned, the said question was never argued before the Tribunal, nor considered by the Tribunal and, as such, it cannot be said that the said question arises from the order of the Tribunal.