(1.) THIS is an Income Tax Reference under section 256(1) of the Income Tax Act, in which following question has been referred to us for our opinion :
(2.) SECTION 154(7) of the Income Tax Act as it stood in the relevant assessment year 1971 -72 states :
(3.) FOLLOWING the aforesaid decisions the question referred to us is answered in the negative, i.e., in favour of the department and against the assessee.