Bharucha, J. - (1.) These are references by the Income-tax Appellate Tribunal to this Court under Section 257 of the Income-tax Act, 1961. The references have been made because of a divergence of opinion between several High Courts.
(2.) The Assessment Year in question in Tax reference Case No. 13 of 1981 is 1973-74; in Tax Reference Cases Nos, 14 and 15 of 1981 they are 1972-73 and 1973-74; and in Tax Reference Case No. 16 of 1981 it is 1972-73.
(3.) The assessee in the three cases is the same. It is a company engaged in the business of generation of electricity and distribution thereof to consumers. It is governed by the Electricity (Supply) Act, 1948.;