JUDGMENT

Syed Shah Mohammed Quadri, J.-This appeal arises from the judgment and order of the Division Bench of the High Court of Judicature for Rajasthan Bench at Jaipur in Income-tax Reference No. 86 of 1987 dated November 9, 1993. The assessee is the appellant.

2. By the order under challenge the High Court answered the following question, referred to it under Section 256(1) of the Income Tax Act, 1961 (for short the Act ), in the affirmative, that is, in favour of the Revenue and against the assessee :

"Whether on the facts and in the circumstances of the case and the business of the assessee being one and indivisible, the Tribunal was right in law in holding that the expenses have to allocated in the same percentage as the different sources of income and are not to be allowed in entirely as allowed by the Commissioner of Income-tax (A) after following decisions noted in para 11 of the order dated 31.1.1985 for the assessment years 1974-75, 1975-76 and 1980-81?"

3. In the assessment year 1977-78 the appellant, a State Government Corporation, derived its income from interest, letting out the warehouses and administrative charges for procurement of foodgrains while working for the Fo