JUDGMENT

S.C. Agrawal, J.-These appeals, by certificate granted under Section 261 of the Income Tax Act, 1961 (hereinafter referred to as the Act ), have been filed by the Godhra Electricity Co. Limited, (hereinafter referred to as the assessee company ) against the judgment of the Gujarat High Court dated February 24-25, 1982 in Income Tax References Nos. 288 of 1975, 73 of 1978 and 171 of 1978. Income Tax Reference No. 288 of 1975 related to the assessment year 1969-70, while Income Tax Reference No. 73 of 1978 related to the assessment years 1970-71 and 1971-72 and Income Tax Reference No. 171 of 1978 related to assessment year 1972-73.

2. On November 19, 1922 the then Government of Bombay granted a licence under the Indian Electricity Act, 1910 to Lady Sulochana Chinubhai & Company Authorising it to generate and supply electricity to the consumers in Godhra area. The assessee-company is the successor of the said licensee. On the recommendations of a Rating Committee constituted under Section 57(2) of the Electricity (Supply) Act, 1948 the State Government had fixed the charges for supply of electricity and motive power by the assessee-company with effect from February 1, 1952.