By an application under Section 256 2 of the Act the Revenue sought a direction to the Tribunal for reference of the following question of law Whether, on the facts and in the circumstances of the case, the Income tax Appellate Tribunal is justified in holding that the agricultural income will number form a part of total income for the purpose of companyputing the accumulation of income in excess of 25 per cent, of the total income as laid down under Section 11 of the Income tax Act, 1961 ?
These appeals impugn the companyrectness of two judgments of the High Court, one dismissing an application under Section 256 2 of the Income tax Act, 1961, for referring a question of law pertaining to the assessment year 1988 89 and the other, dismissing an appeal under Section 260A of the Income tax Act pertaining to the assessment year 1990 91.
