(1.) IN this reference made under s. 26(1) of the GT Act, 1958 (Central Act 18 of 1958) (the Act), the Tribunal, Bangalore Bench, Bangalore (Tribunal), at the instance of the Revenue, has referred the following question of law for the opinion of this Court :
(2.) IN order to appreciate the question referred to us, it is necessary to notice the facts that are not in dispute.
(3.) SRI K. SRInivasan, learned senior standing counsel for the IT Department, assisted by SRI H. Raghavendra Rao, junior standing counsel for the IT Department, appeared for the Revenue. SRI S. P. Bhat, learned advocate, appeared for the assessee.