(1.) THIS reference at the instance of the Revenue raises the following two questions for our determination :
(2.) A few facts which have relevance may now be set out.
(3.) SO far as the first question is concerned, we must answer it in the negative, that is, in favour of the Revenue and against the assessee as it is common ground that the point is covered by the decision of a division Bench of this court in CIT v. Kartikey V. Sarabhai : [1981]131ITR42(Guj) .