1996 (4) TMI 106

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....Act, 1961, in which the following two questions have been referred for our opinion : " 1. Whether, on the facts and in the circumstances of the case, the Tribunal was legally correct in its opinion that loan of Rs. 86,50,000 taken by the corporation created capital asset in the hands of the assessee within the Second Schedule of the Surtax Act, 1964 ? 2. Whether, on the facts and in the circ....