2001 (8) TMI 14

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....t, 1961, seeking a reference of eleven questions. The High Court (see [1999] 238 ITR 177), disposed of the application by a lengthy judgment that concluded by saying that no question of law was found. Among the eleven questions, were questions Nos. 3 and 4, which read thus : "3. Whether the interpretation of the Appellate Tribunal as regards the scope and ambit under section 132(4) is correct ?....

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....challenge needs to be set aside. Mr. K. Parasaran, learned counsel for the assessee, submitted that instead of sending the matter back to the High Court for considering these questions on reference, we should deal with them ourselves because there was a difference of opinion among certain High Courts with regard of the provisions of section 132(4) and the Explanation thereto. We are disinclined....