(1.) AT the instance of the Commissioner of Income-tax (Central), Ludhiana, the Income-tax Appellate Tribunal, Chandigarh Bench, Chandigarh (hereinafter referred to as "the Tribunal"), has referred the following two questions of law to this court for its opinion :
(2.) THE facts relevant to the questions referred to us are :
(3.) WE have heard counsel for the parties. Question No. 1 :