COMMISSIONER OF INCOME TAX Vs. PALANIAPPA DYEING UNIT

JUDGEMENT

(1.) THE applicant has filed this application for grant of leave to appeal to Supreme Court of India in terms of Section 261 of the Income Tax Act, 1961.

(2.) THE factual matrix of the matter lies in a very narrow compass. The applicant filed an application before the Income Tax Appellate Tribunal (for short 'the Tribunal) seeking reference to this Court, the following questions for its opinion:

(3.) THE Tribunal, however, having narrated the factual matrix obtaining therein, in para 5 observed:. . . we are of the opinion that question No. 1 raised by the Revenue is a question of law and arises out of the order of the Tribunal. This question would also cover the other aspects. We accordingly, refer the said question to the Hon'ble High Court for opinion. . .