Deb, J. - (1.) The questions involved in this reference under Section 256(2) of the I.T. Act, 1961, are as follows : " 1. Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the cost price of 55,100 shares should be taken at Rs. 5,51,000 and not at Rs. 1,45,000 ?
(2.) Whether the Tribunal was right in holding that on the facts and in the circumstances of the case, the exchange of one security for another could be described as realisation of the security resulting in profit ? " 2. The statement of the case relates to the assessment year 1963-64, for which the relevant previous year ended on July 31, 1962.
(3.) The assessee is a company. The assessee held 14,500 shares of Asiatic Oxygen & Acetylene Co. Ltd. of the face value of Rs. 10 each as its stock-in-trade. The assessee is a dealer in shares. The aforesaid shares were valued by the assessee at Rs. 1,45,000, i. e., at the cost price at the end of the assessment year 1962-63, and were included in the closing stock.;