COMMISSIONER OF INCOME TAX Vs. NAND MANAHOR AGENCIES

JUDGEMENT

(1.) THIS is an application under Section 256(2) of the Income-tax Act, 1961, for calling for a reference from the Income-tax Appellate Tribunal for resolution of the following questions said to be of law, arising out of the Tribunal's order dated March 17, 1993, in I. T. A. No. 252/Ind of 1991 and C. O. No. 56/Ind of 1991 :

(2.) THIS application has arisen on account of a finding recorded by the Tribunal below that the transaction in question was a debt which has become irrecoverable. The Tribunal in para. 11 of its judgment clearly held :