COMMISSIONER OF INCOME TAX Vs. JEWELLERS ASSOCIATION

JUDGEMENT

(1.) THIS is an application under Section 256(2) of the Income-tax Act, 1961 (for short, "the Act"), wherein a prayer has been made that the following question of law arises out of the order dated June 30, 1989, of the Income-tax Appellate Tribunal, Jaipur Bench, Jaipur (for brevity, "the Tribunal"), and, therefore, the Tribunal be asked to refer the said questions of law for the opinion of this court.

(2.) THE question whether, under a document, the assessee is or is not a charitable trust, is always a question of construction of the document and the question of construction of a document is always a question of law.