(1.) AT the instance of the assessee the Income Tax Appellate Tribunal, Delhi Bench 'E', Delhi (for short the Tribunal) has referred under S. 256(1) of the Income-tax Act, 1961 (for short the Act) the following question, arising out of ITA. No. 3198/Del/1984 for the asst. yr. 1981-82, for our opinion.