1988 (8) TMI 52

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....wing question of law, namely: "Whether, on the facts and in the circumstances of the case, the Tribunal was legally justified in holding that no interest under section 139(8) is chargeable treating the firm as an unregistered firm in a case where no tax is payable by the firm as a registered firm, while Explanation (2) to sub-section (8) of section 139 clearly speaks of determination of tax payab....