(1.) The Income-tax Appellate Tribunal, Ahmedabad Bench-A (hereinafter referred to as "the Tribunal") has referred the following question for the opinion of this court in relation to assessment year 1980-81:
(2.) Heard Mr. M.R. Bhatt, learned Senior Advocate with Mrs. Mauna Bhatt, learned Senior Standing Counsel for the applicant.
(3.) The assessee is an individual. The assessment for the assessment year 1980-81 came to be completed under section 143A of the Income-tax Act, 1961 (hereinafter referred to as "the Act") by the Income-tax Officer. The Commissioner of Income-Tax invoked jurisdiction under section 263A of the Act on 4th March, 1985 and issued a show-cause notice to the assessee for the following reasons: