(1.) THIS is a reference under Section 256(1) of the Income-tax Act, 1961 (hereinafter to be referred to as "the Act"). The question referred to us for our opinion is as follows :
(2.) THE relevant assessment year is 1969-70. THE question referred to us is concluded by the decision of a Full Bench of this court in the case of CIT v. S. K. Sahana & Sons Limited (T. C. Nos. 249 to 251 of 1976 disposed of on May 12, 1987--[1988] 169 ITR 617 (Pat)). In order to show that it is completely covered by that decision, some facts need be stated.