JUDGMENT
U.N. Bhachawat, J.
1. This is an application on behalf of the Department under Section 256(2) of the I.T. Act, 1961 (for short, hereinafter referred to as “the Act”), for framing the following question :
“Whether, on the facts and in the circumstances of the case, there
was any material or evidence before the Appellate Tribunal to come to
the conclusion that 70% of the value of goods was covered by the loan
advanced by the bank itself and thereby reducing the addition of unex
plained investment to 30% of the unaccounted for stocks of the value of
Rs. 11,48,375?”
2. After having heard the learned counsel for the parties and on perusing the order of the Tribunal, we are of the opinion that the proposed question of law does arise. We, therefore, frame the aforesaid question and direct the Tribunal to state the case, for answer, to this court.