(1.) This appeal by certificate arises from the decision of the High court of Calcutta in (Special Jurisdiction Income Tax) Matter No. 9 of 1963 on its file. That was a reference made to the High court under Section 66 (1) of the Indian Income-tax Act, 1922 to be hereinafter referred to as 'the act'. Two questions were referred to the High court by the tribunal. They are-
(2.) The High court answered both these questions in favour of the department and against the assessee. Aggrieved by that decision, the assessee had brought this appeal.
(3.) The relevant assessment year is 1953-54, the previous year ending in September/october, 1952.