(1.) The Revenue has filed this application for referring the following question for the decision of this court :
(2.) It is seen from the order of the Income-tax Appellate Tribunal that the Tribunal followed the decision of this court in J Raghottama Reddy v. ITO [1988] 169 ITR 174 and dismissed the departmental appeals. In the said decision, this court held that
(3.) On a consideration of the afore mentioned argument, we are satisfied that the question of law as stated below arises for the decision of this court though the question framed in the reference application is somewhat different :