(1.) THE Income-tax Appellate Tribunal (Allahabad Bench) referred the following questions for opinion of this court relating to the assessment year 1963-64 :
(2.) IN our opinion, this is purely a finding of fact which has been recorded by the Tribunal and there is no reason to doubt the correctness of the same. We, therefore, answer this question in the affirmative, i.e., in favour of the assessee and against the Revenue.
(3.) THE finding of Appellate Tribunal on this question is as follows :