(1.) THE Judgment of the court was delivered by-
(2.) THESE appeals are brought by certificate from the judg-ment of the Calcutta High court, dated 28th September, 1964, in Income-tax Reference No. 18 of 1961.
(3.) AT the instance of the assessee the following question of law wasreferred to the High court under Section 66(1) of the Income-tax Act, 1922(hereinafter called the Act) :