(1.) IN this case, pursuant to the direction of this court under Section 256(2) of the INcome-tax Act, 1961 (hereinafter referred to as "the Act"), the learned INcome-tax Appellate Tribunal (Patna Bench), Patna, referred the following questions, framed by this court, for opinion :
(2.) FOR answering the questions referred for opinion, it is necessary to state the material facts in brief leading to making the reference.
(3.) IN support of the aforesaid submissions, learned counsel cited the following decisions of the Supreme Court and the High Courts :