PATEL AND COMPANY Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) AT the instance of the assessee, the following question is referred to us for our opinion :

(2.) A few facts need be set out in order to appreciate the contentions urged in support of this reference and those which were urged for repelling the said contentions on behalf of the Revenue.

(3.) THE Income -tax Officer, however, disallowed this claim. On appeal to the Appellate Assistant Commissioner, this disallowance was confirmed. On further appeal to the Income -tax Appellate Tribunal, the disallowance was confirmed following the decision of the Punjab and Haryana High Court in CIT v. Oriental Carpet Mfg. (India) P. Ltd. . The assessee prayed for a reference which was granted and the question set out above has been referred to us.