KIRLOSKAR PNEUMATIC CO LTD Vs. COMMISSIONER OF SURTAX

JUDGEMENT

(1.) THE Income-tax Appellate Tribunal has referred the following questions to this court for its opinion under section 18 of the Companies (Profits) Surtax Act, 1964, read with section 256 (1)of the Income-tax Act, 1961. The first two of the questions are referred at the instance of the assessee and the remaining two at the instance of the Revenue :

(2.) AT the instance of the Revenue :

(3.) (THE questions are renumbered for the sake of convenience ).