(1.) The Income Tax Appellate Tribunal, Allahabad has referred the following question of law under Section 256(1) of the Income Tax Act, 1961, hereinafter referred to as "the Act" for opinion to this Court:
(2.) The present reference relates to the assessment years 1978-79, 1979-80 and 1980-81.
(3.) We have heard Sri R.K. Upadhyay, learned Counsel appearing for the revenue and Sri R.S. Agrawal, learned Counsel appearing for the respondent-assessee.