TMI Blog2000 (3) TMI 17X X X X Extracts X X X X X X X X Extracts X X X X ..... ase are : that a search under section 132 of the Act was conducted from December 12, 1986, to December 15, 1986, at the premises of Pannalal, the father of the respondent-assessee. During the course of that search, certain incriminating documents relating to the assessee's income were found there, which were seized and sealed. Thereafter, the assessee filed the revised returns of income for the four assessment years 1982-83, 1983-84, 1984-85 and 1985-86, respectively. The assessments were completed under section 143(3)/147 of the Act on February 8, 1988, and proceedings under section 271(1)(c) of the Act were also initiated for levy of penalty for concealment of income and/or particulars of the income. For two assessment years, the orders o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of law arising out of the Tribunal's appellate order for referring the same to this court for its opinion, which are as follows : "1. Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal is legally justified in finding that the case of the assessee is covered under the amnesty scheme and that no penalty is leviable in the assessee's case under section 271(1)(c) of the Income-tax Act, 1961 ? 2. Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal is legally justified in observing that the Department as a whole has accepted the contention of the assessee regarding filing of the returns under the amnesty scheme while processing the case for waiver of inter ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of law arise from the Tribunal's orders in each case, which shall sufficiently cover the controversy raised in these proceedings : "1. Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal is legally justified in finding that the case of the assessee is covered under the amnesty scheme and that no penalty is leviable in the assessee's case under section 271(1)(c) of the Income-tax Act, 1961 ?. 2. Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal is legally justified in finding that the case of the assessee is covered by questions Nos. 7 and 19 of Circular No. 431 and answers to such questions ?" Accordingly, these applications under section 256(2) of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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