( 1 ) WHETHER Rule 19a of the Income-tax Rules, 1962, providing for the computation of capital employed in an industrial undertaking or a hotel business for the purpose of Section 80j of the Income-tax Act, 1961, restricts the scope of reliefs under Section 84 of the Income-tax Act, 1961, is the question that falls for consideration in this application under Article 226 of the Constitution.

( 2 ) THE petitioner is Century Enka Ltd. The petitioner carries on business, inter alia, of manufacture, process and sale of polymide, polyester, rayons or any other type of man-made fibres of silk, wool, cotton or any other types of natural fibres. In the year 1969 the petitioner established an industrial undertaking at Ghosari Post, Poona, for the manufacture of and/or process of nylon yarn and other fibres. It is the case of the petitioner that the said undertaking satisfies the conditions laid down by Sub-section (4) of Section 80j of the Income-tax Act, 1961. For the assessment year 1971-72, the relevant previous year for which is the year ending on September 30, 1970, the petitioner submitted its return for assessment to income-tax and the petitioner stated that