(1.) In this reference, two questions have been referred. The questions are as follows
(2.) In view of the decision of this court in the case of CIT v. Kanan Devan Hills Produce Co. Ltd. question No. 1 must be answered, in view of the facts found by the Tribunal, in the negative and in favour of the assessee.
(3.) So far as question No. 2 is concerned, it appears that the AAC gave the following direction: