(1.) This is a reference made by the Income-Tax Appellate Tribunal, Gauhati Bench, Gauhati under section 256 (2) of the Income-Tax Act, 1961, for short 'the Act'.
(2.) In compliance with the direction of the High Court made in Civil Rule 1(M) of 1975, the learned Tribunal drew up the statement of the case and forwarded the same, along with the question which the High Court had formulated for determination. We extract the question:
(3.) Bearing in mind the principles aforesaid let us proceed to dispose of the question referred to us. The relevant facts necessary for answering the question are set out: