1992 (8) TMI 244

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....the appellant under section 256(2) of the Income-tax Act, 1961, for an order directing the Income-tax Appellate Tribunal to state a case and refer the question of law arising out of the Tribunal's order for the decision of the High Court, The question of law is as under : " Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in holding that notice served on A....

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.... in Banarsi Debi v. ITO [1964] 53 ITR 100. The decision of this court in Banarsi Debi was considered and explained in a subsequent decision of this court in R. K. Upadhyaya v. Shanabhai P. Patel [1987] 166 ITR 163. It was pointed out that the meaning of the word " issued " is to be construed in the context and the setting in which it occurs so that its meaning may vary depending on the context. Th....