(1.) The substantial question of law that arises for consideration in this appeal and as framed at the time of admission is as under:
(2.) The assessment year was 1992-1993. The issue centres around the expenses relating to Baramba and Dhenkanal sugar units of the respondent. The respondent is having three different lines of manufacturing activities viz., Sugar Division, Distillery Division and Foundry Division.
(3.) In the Sugar Division, its factory at Sakthi Nagar is situated in Periyar District, Tamil Nadu has been noted as Unit-I, its manufacturing unit at Padamathur, Sivaganga Taluk, P.M.T. District also in Tamil Nadu is called Unit-II and its manufacturing unit at Sunapal, Barambagarh, Cuttack District, Orissa is known as Unit-III.