(1.) THE Income Tax Appellate Tribunal, Allahabad has referred the following two questions under Section 256(1) of the Income Tax Act, 1961 (hereinafter referred to as the Act) for opinion of this Court:
(2.) THE reference relates to the block period from 1.4.1986 to 25.9.1996.
(3.) WE have heard Sri R.K. Upadhyaya, learned standing counsel for the Revenue and Sri S.K. Garg has appeared on behalf of the respondent.