HIND CONDENSORS LIMITED Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) 1. By this reference under Section 256(1) of the Income -tax Act, 1961, at the instance of the assessee, the Income -tax Appellate Tribunal has referred the following question of law to this court for opinion :

(2.) THE facts of the case giving rise to the above controversy briefly stated are as follows :

(3.) WE have carefully considered the rival submissions of learned counsel for the parties. Section 217 of the Act as it stood at the material time, reads as follows :