1986 (8) TMI 50

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....256(2) of the Income-tax Act, 1961, the Commissioner of Income-tax, Allahabad, has made prayer that the Income-tax Appellate Tribunal, Allahabad Bench, Allahabad, may be directed to refer the following three questions to this court for its opinion : " 1. Whether, on the facts and in the circumstances of the case, the order of the Tribunal upholding the deletion of entertainment expenditure is v....

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....on" question No. 1, referred to above, is a question of law which arises from the appellate order of the Tribunal. As regards question No. 2, we are of the opinion that the findings recorded by the Tribunal in the appellate order in regard to this question are findings of fact and the said question cannot be said to be a question of law arising out of the said order. As regards question No. 3, ....