(1.) THE following question has been, at the instance of the Revenue, referred to us by the Income-tax Appellate Tribunal, Cochin Bench :
(2.) IN the light of our decision in I.T.R. Nos. 7 and 8 of 1982 (CIT v. C. Tharian and Sons [1987] 166 ITR 607 (Ker), we answer the question in the negative, that is, in favour of the Revenue and against the assessee.