(1.) This reference application has been filed by the Commissioner of Wealth-tax against the judgment of the Income-tax Appellate Tribunal deciding the reference against the Department and in favour of the assessee. The question which had been referred by the Tribunal is :
(2.) It is evident from the aforesaid question that the dispute was in respect of two assessment years. Hence, two assessment orders were passed by the Wealth-tax Officer followed by two judgments in the appeal.
(3.) On reference having been made, the Bench which heard the same reframed the questions which are as under :