COMMISSIONER OF INCOME TAX Vs. MICHEL GARNAUD

JUDGEMENT

(1.) THE present income -tax reference is at the instance of the Department under s. 256(1) of the IT Act, 1961 (hereinafter 238/Del/1982 for the asst. yr. 1978 -79.

(2.) THE following questions, said to be substantial questions of law, have been referred for the opinion of this Court :

(3.) AFTER perusal of the record we find that documents mentioned as Annexs. A -1 to E, viz., copies of the assessment orders of the five assessees, copy of the consolidated order of the CIT(A), copy of the consolidated order of the Tribunal statement of the case. A foot note has been endorsed along with the statement of case which reads as under :