(1.) THE Income-tax Appellate Tribunal, Chandigarh Bench, at the request of the Commissioner of Income-tax, Patiala, referred the following question of law for decision of this court under Section 256(1) of the I.T. Act, 1961 (hereinafter referred to as "the Act"):
(2.) BRIEFLY the facts which have given rise to this reference are as follows :
(3.) NO amendment was made by the Amendment Act in the aforesaid provisions of Section 271. The amendment was, however, made in Section 274(2). After the amendment, the said sub-section reads as follows: