(1.) THIS is an application for making reference under S. 256(2) of the IT Act, 1961, on the following question of law :
(2.) WE have heard Sri Satish Mandhyan, the learned counsel for the applicant, and Shri Prakash Krishna, the learned counsel for the respondent.
(3.) CONSIDERING the facts and circumstances of the case, we are of the opinion that a substantial question of law arises. We direct the Tribunal, Allahabad, to draw up statement of facts in the present case and refer the question of law as framed above for opinion of this Court.