1996 (12) TMI 8

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....ue sought the reference of the following two questions: "(1) Whether, on the facts and in the circumstances of the case, the Tribunal was right in law, in holding that the Commissioner of Income-tax had no jurisdiction and powers to initiate proceedings under section 263 of the Income-tax Act, 1961, in respect of issues not touched by the Commissioner of Income-tax (Appeals) in his appellate or....