Dipak Kumar Sen, J. - (1.) This reference arises out of income-tax assessment of Kishanlal & Sons (Udyog) Pvt. Ltd., the assessee in the assessment years 1970-71 and 1971-72, the relevant accounting years ending on the 30th April of 1969 and 1970.
(2.) The facts found on record are, inter alia, that the assessee had been carrying on business in loading and unloading iron ores in the past assessment years and owned a jetty and trolly lines which were used in the said business.
(3.) In the assessment year 1970-71, the assessee discontinued its business in iron ore.;