- (1.) WE have heard the learned counsel for the assessee. Sri A.N. Mahajan has appeared for the Department.
(2.) THE following question has been referred to this Court under s. 27(1) of the WT Act for the opinion of this Court : "Whether on the facts and in the circumstances of the case, the Tribunal was justified in law in upholding the view that the assessee was not entitled to the deduction of Rs. 4,78,998 representing the notional amount of capital gains tax?" The above question is covered by the Division Bench decision of the Court in Bharat Hari Singhania and Ors. vs. CWT and Ors. (1994) 118 CTR (SC) 125 : (1994) 207 ITR 1 (SC) (sic). In view the aforesaid judgment the question is answered in affirmative i.e., in favour of the Department and against the assessee.;