Questions of law on income-tax additions and interest directed to be referred, while one issue was excluded.

Questions arising from relief granted by the CIT(A) on additions under section 40A(2), relief on additions under section 43B, and the direction not to charge interest under section 216 were treated as questions of law in an application under section 256(2) of the Income-tax Act, 1961. The HC held that these issues required reference because they involved legal questions, not merely factual disputes. Accordingly, questions 2, 3, and 4 were directed to be referred to the High Court, while question 1 was not referred.

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Issues: Whether, in an application under section 256(2) of the Income-tax Act, 1961, questions relating to additions under section 40A(2), section 43B, and interest under section 216 were questions of law requiring a reference to the High Court.

Analysis: The Court found that the questions concerning the relief allowed by the Commissioner of Income-tax (Appeals) in respect of additions under section 40A(2), the relief allowed in respect of additions under section 43B, and the direction not to charge interest under section 216 raised questions of law.

Conclusion: Questions 2, 3, and 4 were directed to be referred to the High Court, while question 1 was not referred.

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