(1.) WITH respect to the decision rendered by the Income-tax Appellate Tribunal, Cochin Bench in I. T. A. No. 10/(Coch) of 1997, the Revenue framed as many as ten questions for reference to this court under Section 256 of the Income-tax Act, 1961. After considering all the aspects, the Tribunal re-framed and formulated the following question for the answer by this court, viz :
(2.) THE brief facts in this case are as under. THE assessee is a firm doing business in toddy. THE assessment for the year 1986-87 ending with March 31, 1986 is on a total income of Rs. 5,51,700. In the course of assessment, the Assessing Officer had noticed that the following shortages were discovered by the sales tax authorities on the basis of a raid conducted by them on November 6, 1985.
(3.) BEFORE proceeding further it will be appropriate to keep in mind the following dates.