(1.) The following questions have been, at the instance of the revenue, referred to us by the Income Tax Appellate Tribunal, Cochin Bench:
(2.) For the reasons stated by this Court in CIT v. Forbes, Ewart & Figgis (P) Ltd., (1982) 138 ITR 1 (Ker.) : 1981 KLT 483 (FB), question No. (2) is answered in the affirmative, that is, in favour of the assessee and against the revenue.
(3.) For the reasons stated by us in ITR No. 111 of 1981, we answer question No. (3) in the negative, that is, in favour of the revenue and against the assessee.