(1.) THE following question has been referred by the Income-tax Appellate Tribunal (hereinafter referred to as "the Tribunal") to this court for decision :
(2.) THE assessee claimed the deduction of the following liabilities for the assessment year 1971-72 :
(3.) THE argument of learned counsel for the petitioner was that, since the dispute was between the Income-tax Department and the assessee, the burden was on the Department also.