(1.) THE Income-tax Appellate Tribunal has referred the following two questions of law for the decision of this court :
(2.) THE respondent herein is the Revenue. THE original assessee died, pending the reference. His legal heirs have been impleaded as applicants Nos. 1 and 2 as per orders passed by this court in C. M. P. No. 4095 of 1991.
(3.) IN appeal, the Appellate Assistant Commissioner confirmed the said assessment. The assessee took up the matter in second appeal before the INcome-tax Appellate Tribunal.