(1.) This is an application under Section 256(2) of the Income-tax Act at the instance of the Revenue and pertains to the assessment year 1984-85.
(2.) We have heard learned counsel for the parties and we are satisfied that the following two questions are statable questions of law and do arise out of the order of the Income-tax Appellate Tribunal :
(3.) Accordingly, we direct the Income-tax Appellate Tribunal, Delhi Bench 'SMC', New Delhi, to draw up a statement of the case and refer the aforesaid questions for the opinion of this court.