- (1.) BY THE COURT : Heard Mr. Mathur, learned counsel for the appellant. Considering his submissions, in our view the question of law does arise in the questions proposed, therefore, we direct the Tribunal to refer the following questions for the opinion of this Court : "Whether, on the facts and in the circumstances of the case and in law, the learned Tribunal is right in cancelling the penalty levied under S. 271D of the IT Act, 1961, in view of the provisions of s. 269SS of the IT Act, 1961 ?" "Whether, on the facts and in the circumstances of the case and in law, the learned Tribunal is right in cancelling the penalty levied under S. 271E of the IT Act, 1961, in view of the provision of s. 269SS of the IT Act, 1961 ?"
(2.) THE Tribunal is further directed to refer the aforesaid questions along with the statement of the case to this Court within 2 months from the date of receipt of certified copy of this order.;