(1.) THIS is an application on behalf of the Department under Section 256(2) of the I.T. Act, 1961 (for short, hereinafter referred to as "the Act"), for framing the following question :
(2.) AFTER having heard the learned counsel for the parties and on perusing the order of the Tribunal, we are of the opinion that the proposed question of law does arise. We, therefore, frame the aforesaid question and direct the Tribunal to state the case, for answer, to this court.