COMMISSIONER OF INCOME TAX Vs. BERTRAMS SCOTT LTD

JUDGEMENT

(1.) THIS is a consolidated reference initiated by the assessee and also the Revenue by applications under s. 256 (1) of the IT Act, 1961. The following questions have been referred at the instance of the assessee :

(2.) THE following question has been raised at the instance of the Revenue :

(3.) SO far as the question referred at the instance of the Revenue is concerned the same arises form the following observation in the decision of the Tribunal :