P PALANISWAMI Vs. COMMISSIONER OF INCOME TAX MADRAS

JUDGEMENT

(1.) THE Income-tax Appellate Tribunal, Madras Bench, under section 256(1) of the Income-tax Act, 1961, has referred the following questions of law for the opinion of this court : "1. Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the Commissioner's letter constituted information for re-opening the assessment under section 147(b) especially when the Income-tax Officer had referred to the order of the Appellate Assistant Commissioner dated March 5, 1966, for re-opening the assessment ?

(2.) WHETHER, on the facts and in the circumstances of the case, the Tribunal was justified in holding that the Commissioner's letter dated May 13, 1966, constituted information from an extraneous source within the meaning of section 147(b) ?