AMBICA MILLS LIMITED Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) THE Tribunal, Ahmedabad has referred the following eight questions for the opinion of this Court under S. 256(1) of the IT Act, 1961. At the instance of the assessee for both the asst. yrs. 1974 75 and 1975 76 :

(2.) AT the instance of the CIT for both the asst. yrs. 1974 75 and 1975 76 :

(3.) THE relevant assessment years are 1974 75 and 1975 76. The assessee company carries on business of manufacture of textiles, steel tubes, machineries, cylinders and chemicals. The textiles are manufactured by unit Nos. 1 and 2 of Ambica Mills at Ahmedabad and unit No. 3 at Baroda. The steel tubes are manufactured by the unit, Ambica tubes while cylinders are manufactured in the name of Ambica cylinders. The assessee company manufactures machineries in the name of Ambica Machinery while chemicals are manufactured in the name of Ambuja Chemicals. The first three questions are referred at the instance of the assessee for both the assessment years and the two questions referred at the instance of the CIT are also for both the assessment years. The last three questions are referred at the instance of the assessee for the asst. year 1974 75.