(1.) : The Tribunal has referred the following two questions to this Court under s. 256(1) of the IT Act, 1961 :
(2.) QUESTION No. 1 is answered in the affirmative that is against the Revenue and in favour of the assessee following the decision in CIT vs. S.G.P.G. Natala (1980) 16 CTR (Guj) 337 : (1980) 124 ITR 391 (Guj).