(1.) HEARD counsel for the parties.
(2.) BY this application made under S. 256(2) of the IT Act, 1961, the assessee requires us to direct the Tribunal to refer the following questions for the opinion of this Court:
(3.) THE case of the assessee is that the Kuwaiti Dinars had to be sold to private agents, as the Kuwaiti Dinars during the war days were not accepted either by Banks or by recognised agents. There is no explanation in the affidavit that the assessee had to sell Kuwaiti Dinars perforce to private agents, because they were not accepted by any recognised agent in the country. Considering the facts and circumstances of the case, the Tribunal came to the conclusion that the assessee failed to disclose that the investment in the land was from the sale proceeds of the Kuwaiti Dinars.