M.C. Agarwal, J. - (1.) This is an application under Section 256(2) of the Income-tax Act, 1961, praying that the Income-tax Appellate Tribunal, Allahabad, be directed to state a case and to refer the following questions stated to be of law and to arise out of the Tribunal's order dated October 30, 1996, passed in ITA No. 2294 (Alld.) of 1995 for the assessment year 1992-93 for the opinion of this court : "1. Whether the Tribunal was justified in the circumstances of the case to distinguish the audit report obtained under Section 44AB of the assessment year 1992-93 from that of the assessment year 1991-92 and thus arrive at a different conclusion ?
(2.) Whether a qualified audit report by the chartered accountant in the circumstances of the case is invalid and has no sanctity in the eyes of law ?
(3.) Whether the Tribunal was justified in the circumstances of the case in refusing to consider the contention that Section 44AB of the Income-tax Act was not attracted in the case of the corporation since its activities do not fall in the category of business ?;