(1.) AT the instance of the CWT, Kanpur, the Tribunal has referred the following question for our opinion :
(2.) THE assessment years involved in this reference are 1958 -59 and 1959 -60. The Income -tax Investigation Commission had detected a huge amount of concealment of income by the assessee for the asst. yrs. 1939 to 1946. A settlement was arrived at between the assessee and the Department, as a result of which the assessee agreed to be assessed on an amount of Rs. 59,48,714. The break up of this amount was as under : . Rs.
(3.) THE question referred is accordingly answered in the affirmative, in favour of the assessee and against the Department. The assessee is entitled to its costs, which is assessed at Rs. 200. Counsel's fee is assessed at the same figure.