1999 (7) TMI 39

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....Appellate Tribunal to draw up a statement of the case and refer the following questions, stated to be one of law, in respect of the assessment year 1983-84, for the opinion of this court: "1. Whether, on the facts and in the circumstances of the case, the Tribunal was right in law and in facts in holding that the Explanation added to section 9(1)(ii) is a substantive amendment and not clarificato....

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.... deduct or deposit income-tax on the said amount under section 192 of the Act. This fact came to the notice of the Revenue during search operations conducted at the premises of the assessee. The Income-tax Officer levied penal interest under section 201(1A) of the Act for non-deduction of tax by the assessee on the aforenoted amount. The assessee's appeal to the Commissioner of Income-tax (Appeals....