BHARUCHA, J. - (1.) THESE are references under section 256(1) of the Income -tax Act, 1961, made at the instance of the Revenue. Two common questions are posed, namely : '(1) Whether, on the facts and in the circumstances of the case, the Data Processing Machines are office appliances and are, therefore, ineligible for the allowance of development rebate to the assessee for the assessment years 1967 -68, 1968 -69, 1969 -70, 1970 -71 and 1971 -72 ? (2) Whether, on the facts and in the circumstances of the case, the devaluation loss of Rs. 42,44,932 is an allowable revenue loss in the assessment year 1967 -68 ?'
(2.) COUNSEL are agreed that the answer to be given to the first question is covered by the decision of this court in the assessee's own case in CIT v. I. B. M. World Trade Corporation : [1981]130ITR739(Bom) . The first question shall, accordingly, be answered in the negative and in favour of the assessee. The facts that are set out are in relation to the second question.
(3.) THE assessment years involved are 1967 -68 to 1971 -72. The method of accounting followed by the assessee is the mercantile system.;