1991 (3) TMI 46

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....me-tax Act, 1961, the assessee is seeking to refer the following five questions : "1. Whether, on the facts and circumstances of the case, the Tribunal is legally justified in upholding the additions of Rs. 2,07,023 towards the value of the jewellery, in the hands of the applicant under section 69A of the Income-tax Act ? 2. Whether, on the facts and in the circumstances of the case, the Tribuna....

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....application under section 256(1) and moreover it is only a general question. It cannot, therefore, be referred. So far as questions Nos. 2, 3 and 5 are concerned, they relate to the same factual issue, namely, whether a particular jewellery found during the search of the assessee's premises under section 132 of the Act belonged to him or to a third party. At the time of search, he or his wife did....