- (1.) The Income Tax Appellate Tribunal, Delhi pas referred the following question of law under Section 256(1) of the Income Tax Act, 1961 (hereinafter referred to as "the Act") for opinion to this Court:- "Whether on the facts and in the circumstances of the case the Tribunal was correct in law to hold that amendment in Section 263 incorporated w.e.f. 1.6.1988 was inapplicable to a case in respect of which the period of limitation had already expired at the time of amendment?"
(2.) The Reference relates to the Assessment Year 1981-82.
(3.) Briefly stated the facts giving rise to the present Reference are as follows:;