JUDGMENT Puttaswamy, J. 1. As the questions that arise for determination in these cases are common, we propose to dispose of them by a common order. 2. In these petitions made under section 261 of the Income-tax Act, 1961, ("the Act"), the petitioner, who was the appellant in Income-tax Appeals Nos. 18, 19, 20 and 17 of 1976, has sought for certificates of fitness to appeal to the Supreme Court of India against our order made in those cases on March 6, 1985. On these petitions, the office has raised an objection as to their maintainability under section 261 of the Act. We have perused the office objection and heard Sriyuths K. Srinivasan and G. Sarangan, learned counsel for the petitioner in these cases, and Sri S. P. Bhat, learned advocate, who had taken notice for the respondent in each of these cases on the same. 3. Sriyuths Srinivasan and Sarangan contend that the terms "any judgment of the High Court delivered on a reference" occurring in section 261 of the Act comprehend all order made on an appeal under Chapter XX-A of the Act and, therefore, these petitions were maintainable under that provision. 4. Sri Bhat in supporting the office objection contends that the plain language of section 261 of the Act does not comprehend an order made on an appeal under Chapter XX-A of the Act. Section 261 of the Act, on the construction of which the question turns reads thus : "An appeal shall lie to the Supreme Court from any judgment of High Court clelivered on a reference made under section 256 in any case in which the High Court certifies to be a fit one for appeal to the Supreme Court." 5. This section in very clear and unambiguous terms, empowers a High Court to grant a certificate of fitness to appeal only on a reference made to the High Court under section 256 of the Act. The scope and ambit of a reference under section 256 of the Act is entirely different from that of an appeal provided under Chapter XX-A of the Act. The words "on a reference made under section 256" occurring in section 261 of the Act cannot, by any stretch of imagination, be interpreted as an appeal made under Chapter XX A of the Act. The words "on a reference made under section 256" occurring in section 261 of the Act cannot, by any stretch of imagination, be interpreted as an appeal made under Chapter XX A of the Act. The omission to include an order made under Chapter XX-A of the Act is somewhat unintentional and is even strange. But that legislative omission cannot be supplied by courts. We are of the view that Parliament had to take note of this omission and remedy the situation. On this view, the objection raised by the office is correct and has to he upheld. We have, therefore, no choice except to dismiss these petitions as not maintainable. 6. But at this stage, Sriyuths Srinivasan and Sarangan, relying on the observations of the Full Bench in Keshava S. Jamkhandi v. Ramachandra S. Jamkhandi, make oral applications for certificates of fitness to appeal to the Supreme Court under articles 133 and 134A of the Constitution on the ground that the cases decided by us raise substantial questions of law of general importance and they need to be decided by the Supreme Court. Sri Bhat, opposing the oral applications, contends that the questions decided by us are essentially on questions of fact and do not raise any substantial questions of law of general importance which need to be decided by the Supreme Court. 7. In Keshava S. Jamkhandi's case, Malimath J. (as his Lordship then as), speaking for the Full Bench, has expressed that the question, when an oral application is made, has to be decided on the facts and circumstances of each case. 8. We are informed that these petitions are the very first petitions made before this court under section 261 of the Act in proceedings arising under Chapter XX-A of the Act and thus there was no occasion for the Supreme Court or this court to express its opinion. WE are of the view that on the facts and circumstances of these cases, it is proper to entertain the present oral applications made before us and deal with them on merits. WE accordingly proceed to deal with them on merits. We have perused our order made in I.T.A. Nos. WE are of the view that on the facts and circumstances of these cases, it is proper to entertain the present oral applications made before us and deal with them on merits. WE accordingly proceed to deal with them on merits. We have perused our order made in I.T.A. Nos. 18, l9 and 20 of 1976 and 17 of 1976, IAC v. N. Vajram Setty [1986] 159 ITR 742 (Kar) affirming the order of the Income-tax Appellate Tribunal on the ground that the same does not raise a question of law. We are of the view that our orders in I.T.A. Nos. 18 to 20 1976, IAC v. N. Vajram Setty [1986] 159 ITR 742 (Kar) and I.T.A. No. 17 of 1976, IAC v. National Flag Perfumery Works [1986] 159 ITR 737 (Kar) do not raise substantial questions of law of general importance that need to be decided by the Supreme Court of India. We cannot, therefore, grant the oral applications made by the petitioner. 9. In the light of our above discussion, we make the following orders and directions : (i) We uphold the office objection raised in these cases and dismiss the SCLAPs filed by the petitioner under section 261 of the Act as not maintainable. (ii) We reiect the oral applications made by the petitioner for grant of a certificate of fitness to appeal against our orders in I.T.A. Nos. 18 to 20 of 1976 and I.T.A. No. 17 of 1976 under articles 133 and 134A of the Constitution on merits. 10. We, however, direct the parties to bear their own costs.