JUDGMENT

RAMASWAMI J.-- This appeal is brought, by special leave, from the judgement of the Allahabad High Court dated April 4, 1963, in Misc. I. T. Application No. 453 of 1960, holding that no question of law arises out of the order of the Income-tax Tribunal and dismissing the application of the appellant under section 66(2) of the Income-tax Act, 1922 (hereinafter called the " Act ").

The respondent is a private limited company carrying on the business of manufacture and export of carpets having their head office at Bhadohi which was formerly in the State of Banaras. The respondent used to obtain yarn from a firm known as Allahabad Woollen Mills at Allahabad for the purpose of its business, viz., the manufacture and export of carpets. The Allahabad Woollen Mills supplied yarn to the respondent for three years ending March 31, 1947, March 31, 1948, and March 31, 1949. While making the assessment of the Allahabad Woollen Mills for the assessment years 1947-48, 1948-49 and 1949-50, the Income-tax Officer held that the goods were supplied by the Allahabad Woollen Mills to the respondent at a lower rate and profit, to that extent, had been diverted. In making the assessments of the All