- (1.) The Income-tax Appellate Tribunal, Delhi has referred the following two questions of law under Section 256(1) of the Income-tax Act, 1961, hereinafter referred to as "the Act" for opinion to this court: 1. Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was legally correct to hold that the salary paid to the assessee for the laid off period outside India was not chargeable to the Indian Income-tax Act in terms of Section 9(1)(ii) of the Income-tax Act, 1961 ?
(2.) Whether, on the facts and in the circumstances of the case the Income-tax Appellate Tribunal was legally correct to hold the order of the lower authorities as erroneous and unjustified ? 2. The present reference relates to the assessment year 1984-85.
(3.) Briefly stated the facts giving rise to the present reference are as follows:;