(1.) BY this reference application under s. 256(1) of the IT Act, 1961, Tribunal has referred the following questions for our opinion :
(2.) NARENDRA Kumar Soorana (Individual), Mannalal Soorana (Individual) and Nirmal Kumar Soorana (HUF) became partners in the firm and contributed cut and processed stones as follows :
(3.) IN the result, we answer question Nos. 1 and 3 in affirmative i.e., in favour of the assessee and against Revenue. So far as the question No. 2 is concerned, we answer that the finding of the Tribunal is not perverse and that is also in favour of the assessee and against the Revenue. Name Name of the firm Contribution (Rs.) Date Mannalal Soorana M/s Hazarimal Milapchand Soorana 20.40 lacs 8-12-1976 Nirmal Kumar Soorana M/s Mannalal Nirmal Kumar Soorana & Co.15.81 lacs 4-1-1976 Narendra Kumar Soorana M/s Mannalal Nirmal Kumar Soorana & Co. 15.37 lacs 4-1-1976