HEMRAJ NEBHOMAL SONS Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) THE decision rendered in this reference shall also govern the disposal of reference being IT Ref. No. 7 of 2000, as both the references involve identical points.

(2.) THIS is an income-tax reference made under Section 256 (1) of the IT Act at the instance of assesses by the Tribunal (ITAT) in RA No. 135/136/ind/1997, dt. 13th March, 2000, which in turn arise out of an appellate order dt. 1st Sept. , 1997, passed in ITA No. 917/918/ind/1993 to answer following two questions of law said to arise out of the aforesaid appellate order :

(3.) HEARD Shri S. C. Bagadia, learned senior counsel with Shri D. K. Chhabra, learned counsel for the applicant/assessee, and Shri R. L. Jain, learned senior counsel with Ku. V. Mandlik, learned counsel for the non-applicant/revenue.