K. Shivashankar Bhat, J.—In respect of the assessment year 1980-81 and 1981-82, the questions referred respectively read as follows :

"1. Whether, on the facts and in the circumstances of the case, the Appellate Tribunal is right in law in confirming the orders of the Commissioner of Income Tax (Appeals) who held that the assessee is, entitled to weighted deduction under section 35B in respect of expense incurred on delegation, export promotion, compliments, etc. ? (Question of 1980-81)

2. Whether, on the facts and in the circumstances of the case, the Appellate Tribunal is right is right in law in confirming the order of the Commissioner of Income Tax (Appeals) who held that the assessee is entitled to weighted deduction under section 35B in respect of delegation expenses of Rs. 3,03,954 and the expenditure on complimentary articles given to foreign delegates amounting to Rs. 32,280 ?" (Question of 1981-82)

2. Though the questions are differently worded, there is no dispute that the answer in I. T. R. C. No. 75 of 1991 would govern the question referred in I. T. R. C. No. 20 of 1991 also.

3. The assessee is engaged in export of goods. This is an admitted position. The assesse