(1.) HEARD learned counsel for the parties.
(2.) THE substantial question of law which arises for consideration in this case as suggested by the appellant is as under : "Whether, on the facts and circumstances of the case, the Tribunal was right in holding that filing of the audit report under s. 32AB(5) during the assessment proceedings and not along with the return of income would satisfy the requirements of the aforesaid section -
(3.) THE brief facts of the case are that the respondent -assessee had submitted his return declaring total income of Rs.