(1.) THE only question that is referred to us at the instance of the Revenue reads thus :
(2.) THE question, counsel agreed, has to be answered in the negative and in favour of the Revenue having regard to the judgment of the Supreme Court in Purshottam N. Amarsay & Anr. vs. CWT 1972 CTR (SC) 255 : (1973) 88 ITR 417 (SC). THE question is accordingly so answered.