COMMISSIONER OF INCOME TAX Vs. ASSAM FRONTIER TEA LIMITED

JUDGEMENT

(1.) IN this reference under Section 256(1) of the INcome-tax Act, 1961 (for short "the Act"), the following three questions have been referred by the INcome-tax Appellate Tribunal for the opinion of this court :

(2.) WHETHER the Tribunal did not err in facts as well as in law in holding that Rule 6AA which was stated to be substantive law and which was brought into the statute with effect from August 1, 1981, would apply in respect of expenses incurred on or before June 30, 1980 ?

(3.) WE have heard Mr. G. K. Joshi, learned senior standing counsel appearing on behalf of the Revenue, and Dr. A. K. Saraf, learned counsel appearing on behalf of the assessee.