Sikri, J. - (1.) This appeal by special leave is directed against the judgment of the High Court refusing to direct the Income-tax Appellate Tribunal to state a case under section 66(2) of the Income Tax Act, 1922, hereinafter referred to as "the Act". The only question which falls for consideration is whether a referable question of law arises or not out of the order of the Appellate Tribunal, B-Bench, Calcutta, dated May 21, 1962.
(2.) It may be mentioned that the only order of the High Court which appears on record is a formal order containing no reasons for dismissing the petition of the Commissioner of Income-tax under section 66(2) of the Act.
(3.) The facts, in brief, are as follows :;