(1.) THE two questions that are referred at the instance of the Revenue read thus :
(2.) COUNSEL are agreed that both questions must be answered in the affirmative and in favour of the assessee, in view of the judgment of this Court in Indian Oil Corporation Ltd. vs. S. Rajagopalan, ITO (1973) 92 ITR 241(Bom). Accordingly, the questions are so answered. No order as to costs.