(1.) THE following question has been referred under s. 226(1) of the I.T. Act, 1961 by the Income-tax Appellate Tribunal, Bangalore Bench :
(2.) THE facts behind the legal formulation have been set out in the statement of facts and may briefly be summarised as follows :
(3.) ON November 3, 1974, a new deed of partnership was executed with five partners inclusive of Sri. A. Ramakrishna Rao and it continued the same old business with effect from November 1, 1974.