1996 (3) TMI 102

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....eference, under section 256(2) of the Income-tax Act, 1961, of the following questions : " 1. (i) Whether, on the facts and in the circumstances of the case, is the assessee engaged in manufacture or production of any article or thing and is not the above finding wrong and unreasonable ? (ii) Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in holding....

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....e appellate authority placed reliance on the earlier order dated August 7, 1986, for the assessment year 1983-84, whereby deduction under section 80-I was granted in favour of the assessee. The Tribunal in paragraph 3 of the order also relied on its earlier order for the years 1983-84 and 1984-85 having been passed on December 16, 1992, to contend that the assessee would be entitled to deduction u....

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....considered, in view of the position, in the light of the test laid down by the decision of the Supreme Court as also the contention as to whether any application to the provisions of the Central Excises and Salt Act, 1944, the conclusion reached can bodily govern the question involved being one under the Income-tax Act, 1961. The question is a question of law and also of importance. The Income-....