(1.) HEARD Sri R.S. Agarwal for the assessee and Sr Bharat Ji Agarwal and Sri A.N. Mahajan for the Department.
(2.) THIS is a reference under S. 27(1) of the WT Act in which the following question has been referred to us for our opinion :
(3.) IN view of the above, we answer the question No. 1 as reframed by us in the affirmative and question No. 2 in the negative i.e., in favour of the Department and against the assessee.