(1.) THE question that arises for consideration reads thus :
(2.) COUNSEL are agreed that the answer to be given to the question is covered by our judgment in Trustees of Kilachand Devchand Foundation vs. CIT (1987) 63 CTR (Bom) 104: (1988) 172 ITR 382(Bom). Following that judgment, the question is answered in the negative and in favour of the assessee. No order as to costs.