(1.) THE Income-tax Appellate Tribunal has referred the following two questions of law arising out of its order dated October 21, 1980, in respect of the assessment years 1965-66 to 1974-75 :
(2.) THE brief facts of the case are that the assessee filed his returns in the status of individual. After the death of the assessee, the legal representatives of the assessee submitted revised returns and excluded the value of the property known as Barwara House located at Civil Lines, Jaipur. THE returns under the Wealth-tax Act, 1957, were filed declaring the said property as owned by the Hindu undivided family.
(3.) THE submission of learned counsel for the petitioner is that the order of the Tribunal for the assessment years 1957-58 to 1964-65 dated February 19, 1972, does not operate as res judicata as it is not a court of competent jurisdiction and is only a departmental authority.