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1999 (2) TMI 14

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....essment years, are common. They read thus : "(1) Whether the Tribunal is right in law and on facts in deleting the addition under section 40A(5) of the Income-tax Act, 1961, in respect of premium paid for the purchase of deferred annuity policies in respect of two managing directors ? (ii) Whether the Appellate Tribunal is right in distinguishing the decision of the Gujarat Steel Tubes Ltd.'....

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....as therefore, a question of law to be considered and the High Court ought to have called upon the Tribunal to refer the questions to it for determination. Learned counsel for the assessee, fairly, did not dispute that, in any event, the questions of law arose which required determination by the High Court. We make it clear that we do not express any view on the questions but, clearly, the quest....