(1.) THE following question is referred by the Income-tax Appellate Tribunal for the opinion of this court under Section 256(1) of the Income-tax Act, 1961 (briefly "the Act") :
(2.) THE facts, as stated in the statement of the case, are that in the business, known as Johns Mills, there were four groups with the share ratio as follows : <FRM>JUDGEMENT_12_ITR234_1998Html1.htm</FRM>
(3.) ON further appeal, the Appellate Tribunal agreed with the Appellate Assistant Commissioner.