( 1 ) THIS is a composite reference under Section 66 (1) of the Indian Income-tax Act, 1922, by the Income-tax Appellate Tribunal, Calcutta, to this court whereby a consolidated statement of the case has been submitted in response to applications by both the Commissioner and the assessee. The assessee is M/s. Tea Estates India Private Ltd. and the assessment year concerned is 1956-57, the corresponding accounting year ending on the 30th June, 1955. The assessee held 52,350 shares out of the total issued shares of 54,600 in M/s. Dibru Darrang Tea Company Ltd. (hereinafter referred to as "d. D. T. Co. ") and 22,998 shares out of the total issued shares of 23,000 in M/s. Taikrong Tea Company Ltd. (hereinafter referred to as "t. T. Co. " ). The latter two companies were tea companies growing, manufacturing and selling tea for which purpose they owned large tea estates containing land, buildings, plant, machinery, etc. On the 11th August, 1947, the two tea companies sold their entire tea estates, including all the assets, to M/s. Brooke Bond Estates India Ltd. , and on such sales D. D. T. Co. received a surplus of Rs. 17,18,061 over the book value of its assets and T. T.