(1.) THE following two substantial questions of law have been referred for our opinion :
(2.) INSOFAR as the first question is concerned, it is required to be decided in the affirmative, in favour of the Revenue and against the assessee in view of the decision of the Supreme Court in CIT vs. N.C. Budharaja & Co. (1993) 114 CTR (SC) 420 : (1993) 204 ITR 412 (SC). The second question does not arise in view of the above.