JUDGMENT : 1. Om Prakash, J.: These are applications relating to the asst. yrs. 1975-76 and 1976-77 by the assessee-applicant. Upon perusal of the orders of the Tribunal, we are of the view that the following common question of law arises from the Tribunal's order in both the applications : "(i) Whether, on the facts and circumstances of the case, the IT authorities and the Tribunal were right in holding that the penalty under s. 18(1)(c) of the WT Act, 1957, was leviable on the assessee ?" 2. The Tribun+l is, therefore, directed to draw up a statement of case and refer the aforesaid common question of law for the opinion of this Court. Both the applications are partly allowed.