(1.) THIS is a reference at the instance of the Revenue. The two questions which are raised read thus :
(2.) COUNSEL are agreed that the answer to be given to the first question is concluded by the Full Bench judgment of this Court in CIT vs. Carona Sahu Co. Ltd. (1984) 38 CTR (Bom) 219 : (1984) 146 ITR 452. Following that judgment, the question is answered in the negative and in favour of the Revenue.