(1.) HAVING heard learned counsel for both the parties, we are of the opinion that the following two questions of law do arise from the order of the Tribunal and shall, therefore, be stated under Section 256(2) of the Income-tax Act, 1961 :
(2.) WE may mention that, in his application, the petitioner has asked for referring three questions but, before the Tribunal, in his application under Section 256(1), he had requested only questions Nos. (ii) and (iii) alone to be referred and those are the questions which we have now directed to be referred.