(1.) THE Tribunal, Delhi has referred the following two questions of law under s. 27(3) of the WT Act, 1957 (hereinafter referred to as the Act) for opinion to this Court : "1. Whether on the facts and in the circumstances of the case, the Tribunal was legally justified in upholding the order of the AAC annulling the assessment ?
(2.) WHETHER , on the facts and in the circumstances of the case, the Tribunal was legally justified in not pronouncing the decision on merits of the case - 2. Briefly stated the facts giving rise to the present reference are as follows : The reference relates to the asst. yr. 1977 -78.
(3.) WE have heard Shri Govind Krishna, the learned standing counsel for the Revenue and Shri Amitabh Agrawal, learned counsel holding brief of Shri P.K. Jain.