COMMISSIONER OF INCOME TAX Vs. S.K. GUPTA

JUDGEMENT

(1.) THE Tribunal, Allahabad has referred the following questions of law under s. 256(1) of the IT Act, 1961 (hereinafter referred to as "the Act") for opinion to this Court :

(2.) THE reference relates to the asst. yrs. 1974 -75 and 1976 -77.

(3.) BRIEFLY stated, the facts giving rise to the present reference are as follows :