TMI Blog1996 (1) TMI 85X X X X Extracts X X X X X X X X Extracts X X X X ..... x, Bhopal, has filed this application under section 256(2) of the Income-tax Act, 1961 (for short, "the Act"), seeking a direction to the Income-tax Appellate Tribunal, Indore, to state the case and refer the proposed question of law, as extracted below, to this court arising out of its order dated July 8, 1994, passed in I. T. A. Nos. 288 and 781/(Ind) of 1992 : " Whether, on the facts and in t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cer rejected the explanation of the assessee and passed the order. The additions were, however, set aside in the first appeal. The Tribunal found it fit to delete the additions. Aggrieved by the order of the Tribunal, the applicant filed an application under section 256(1) of the Act. This application, registered as R. A. No. 98/(Ind) of 1994 was rejected on December 12, 1994. Thereafter, the appl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Sons [1971] 79 ITR 499 (SC), where the Tribunal reaches a conclusion in regard to the aforesaid aspects, which is one of fact, it does not give rise to any question of law as such. Counsel for the applicant is, thus, unable to show as to how the proposed question is a question of law. The conclusion is based on appreciation of facts and is not shown to be infirm or perverse. In the result, we ..... X X X X Extracts X X X X X X X X Extracts X X X X
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