(1.) The following question of law was referred to the High Court :
(2.) The High Court answered the question in favour of the assesses relying on the decision in the case of CIT v. Cibatul Ltd.,1978 115 ITR 879 . This judgment has been approved by this court in the case of CIT v. Alcock Ashdown and Co. Ltd., 1997 224 ITR 353 . In view of the aforesaid, the appeal is dismissed. There will be no order as to costs.