(1.) IN this reference at the instance of the Revenue under S. 64(1) of the ED Act, 1953 (hereinafter referred to as `the Act'), the following two questions of law are referred for the opinion of the Court :
(2.) THE facts as found in the statement of case are as follows :
(3.) IN the view we have taken above, the answer to both the questions is in the negative and in favour of the Revenue.