Dipak Kumar Sen, J. - (1.) The material facts and proceedings leading up to the present reference are as follows :
(2.) Union Carbide India Ltd., the assessee, carries on business of manufacture of various products. In the assessment year 1975-76, the relevant accounting year ending on December 25, 1971, the assessee acquired some trawlers with sophisticated equipment like echosounders, electronic fish finding equipment, trawlers, radars, etc., for deep sea fishing and set up a "Deep Sea Fishing Division" for fishing shrimps in the deep sea.
(3.) The trawlers and the equipments were utilised not only for fishing but also for decapitating, peeling and packing shrimps in special containers and freezing them in special quick-freezing chambers installed in the vessels.;