(1.) THE Income-tax Appellate Tribunal, Allahabad Bench, Allahabad, has referred the following questions of law stated to he arising out of its combined order dated September 19, 1977, passed in I. T. A. Nos. 645 and 646 (Allahabad) of 1976-77 :
(2.) WE have heard learned counsel for the assessee, Sri R.S. Agarwal and learned counsel for the Revenue, Sri Ashok Kumar.
(3.) THE Tribunal further observed :