- (1.) BY this application under Section 256(2) of the Income-tax Act, 1961, the Revenue requires us to direct the Appellate Tribunal to refer the following question for the opinion of this court ; " Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was legally correct and justified in cancelling the interest of Rs. 11,86,926 charged under Section 201(1A) for the assessment year 1984-85 ?"
(2.) AFTER hearing the argument of both the parties, we are of the view that the aforesaid question is a question of law and we, therefore, direct the Income-tax Appellate Tribunal to draw up a statement of case and refer the above question for the opinion of this court. The application is, accordingly, allowed.;