(1.) THIS appeal arises out of the Income-tax Reference No. 54 of 1978 (see (All)), wherein the Income-tax Appellate Tribunal, Delhi Bench, had referred the following questions to the Allahabad High Court for opinion :
(2.) THE Allahabad High Court by its impugned judgment dated January 28, 1980, has answered the said questions against the assessee and in favour of the Revenue. Hence, this appeal.