(1.) BOTH these references were heard together and it will be convenient to dispose them of by a common order, for, the arguments in both the references are identical.
(2.) WE may first notice the facts leading to REFERENCES NO 9 OF 1977:
(3.) HAVING considered the contentions of the learned counsel for the Revenue as well as that of assessees in respect of Explanation-2 of s. 37 (2a), we are of opinion that the questions referred by the Tribunal should be answered having regard to s. 37 (2b) as it existed during the assessment years 1972-73. 1973-74 and 1974-75.