1994 (2) TMI 9

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....tion under section 256(2) of the Income-tax Act, 1961 (for short, "the Act"), filed by the assessee against the order dated January 20, 1993, passed by the Income-tax Appellate Tribunal, Gauhati Bench, in Income-tax Reference No. 163/(Gau) of 1991 arising out of I. T. No. 152/(Gau) of 1990 for the assessment year 1985-86 rejecting the reference application filed by the assessee under section 256(1....

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....lied upon by the assessee before the lower authorities and before the Tribunal ? 3. Whether, on the facts and in the circumstances of the case, the Tribunal committed a manifest error of law in confirming the penalty imposed under section 271(1)(c) of the Income-tax Act, 1961, solely on the basis of reasons given in the assessment order and without considering the entirety of the facts and circ....