Judgement

JUDGMENT :- This appeal arises out of the Income Tax Reference No. 543/77 where the four questions that were referred to the Allahabad High Court by the Income Tax Appellate Tribunal (hereinafter referred to as the Tribunal) have been answered by the High Court against the assessee and in favour of the Revenue. Insofar as questions Nos. 1, 3 and 4 are concerned, the High Court has mentioned that the learned counsel for the assessee had conceded, that questions Nos. 1 and 3 were covered by the decision of the Full Bench of the said High Court in Saraya Sugar Mills (P) Ltd. v. Commr. of Income-tax, 116 ITR 387 : (AIR 1978 Allahabad 405) and that question No. 4 was covered by the decision of the Full Bench in the Commr. of Income Tax v. Ram Gita Kali Ram, 121 ITR 708 : (1980 Tax LR 40) decided on August 23, 1979.

2. We have heard Shri Mahajan, the learned counsel appearing for the appellant/assessee in support of the appeal and Shri G. C. Sharma, the learned senior counsel appearing for the revenue. Insofar as questions Nos. 2 and 4 are concerned Shri Mahajan has not been able to show any infirmity in the impugned judgment of the High Court. As regards questions Nos. 1 and 3 S