R.M. Sahai, J. - (1.) HAVING heard learned counsel for the assessee and learned standing counsel for Income-tax Department, we are of the opinion that the following questions of law do arise out of the order passed by the Income-tax Appellate Tribunal, Delhi Bench "B", New Delhi: "(1) Whether, on the facts and circumstances of the case, the Tribunal is right in upholding the order of Commissioner of Income-tax, Meerut, under Section 263 of the Income-tax Act, 1961 ? (2) Whether the Tribunal's finding is vitiated in law in doubting the market value of plant and machinery without any material and ignoring the materials on record ?"
(2.) WE, accordingly, direct the Tribunal to draw up a statement of the case and submit the same to this court.;