1999 (2) TMI 14

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..... thus : "(1) Whether the Tribunal is right in law and on facts in deleting the addition under section 40A(5) of the Income-tax Act, 1961, in respect of premium paid for the purchase of deferred annuity policies in respect of two managing directors ? (ii) Whether the Appellate Tribunal is right in distinguishing the decision of the Gujarat Steel Tubes Ltd.'s case [1994] 210 ITR 358 ?" It is diff .....

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..... ered and the High Court ought to have called upon the Tribunal to refer the questions to it for determination. Learned counsel for the assessee, fairly, did not dispute that, in any event, the questions of law arose which required determination by the High Court. We make it clear that we do not express any view on the questions but, clearly, the questions are questions of law and their considerat .....

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