(1.) HEARD Mr. S.N. Ratho, learned counsel for the petitioner, and Mr. A.K. Ray, learned counsel for the Revenue.
(2.) AT the instance of Mr. A. Venkata Rao (hereinafter referred to as "the assessee"), the Income-tax Appellate Tribunal, Cuttack Bench, Cuttack (hereinafter referred to as "the Tribunal"), has referred the following two questions for the opinion of this court under Section 256(1) of the Income-tax Act, 1961 (in short, "the Act") :