(1.) THE question referred to us is:
(2.) FOLLOWING the decision in R. C. N. 65 of 1980 dated 22-11-1984 (CIT v. Udayalaxmi Hardware Stores MANU/ap/0050/1984,, [1990 ]183 ITR159 (AP ), the question is answered in the negative, i. e. , against the assessee and in favour of the Revenue. No. costs.
(3.) [the Supreme Court has dismissed the special leave petition filed by the assessee against this judgment: See [1989] 180 ITR (St.) 39 - Ed. ]