- (1.) The Tribunal, New Delhi, has referred the following questionslaw under Section 256(1) of the IT Act, 1961. hereinafter referred to as the Act, for opinion to this Court. "1. Whether, on the facts and in the circumstances of the case, the Tribunal was correct in law in allowing investment allowance under Section 32A of the IT Act, 1961, on the machinery installed in assessee's cold storage ? 2. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in law in holding that the cold storage plant is entitled to investment allowance when the Department's reference application in the case of M/s Car Cold Storage. Shahjahanpur in R.A. No. 331/All/1984, dt. 18th July, 1984 is pending decision of Allahabad High Court on similar issue ?"
(2.) The reference relates to the asst. yr. 1980-81.
(3.) We have heard the learned counsel for the parties.;