(1.) ON being directed by this court under Section 256(2) of the I.T. Act, 1961, the Patna Bench of the Income-tax Appellate Tribunal has made a statement of the case on the following two questions, as formulated by this court :
(2.) THE relevant facts lie in a short compass : THE matter relates to the levy of penalty under Section 271(1)(c) of the I.T. Act, 1961, for the assessment year 1969-70.
(3.) THE Tribunal having confirmed the levy of penalty under Section 271(1)(c), the aforesaid two questions arise for the opinion of this court.