(1.) BY this reference under Section 256(1) of the I.T. Act, 1961 (hereinafter referred to as " the Act"), the Income-tax Appellate Tribunal, Indore Bench, has referred the following question of law to this court for its opinion:
(2.) THE material facts giving rise to this reference briefly are as follows :
(3.) FOR all these reasons, our answer to the question referred to this court is in the affirmative and against the Department. In the circumstances of the case, parties shall bear their own costs of this reference.