AJIT K. SENGUPTA, J.

( 1 ) AT the instance of the assessee, the following common questions of law have been referred to this court for the assessment years 1968-69 and 1969-70 :" (i) Whether, on the facts and in the circumstances of the case and having regard to the fact that the assessee is a sterling company maintaining accounts in pound sterling, the Tribunal was right in holding that for the purpose of computation of the admissible amounts of depreciation under Section 32 (l) (iii) and/or development rebate and profit under Section 41 (2) of the Act for the assessment years 1968-69 and 1969-70, the written down value of the fixed assets should be determined, not in pound sterling, but in equivalent amount of rupees ? (ii) Whether, on the facts and in the circumstances of the case, a revision of the written down value of the assets comprising service lines acquired prior to April 1, 1961, which written down value had been correctly arrived at under the Indian Income-tax Act, 1922, was required for the assessment years 1968-69 and 1969-70 by virtue of the definition of 'actual cost' introduced by the Income-tax Act, 1961, with effect from the assessment year 1962-63 ? (iii) Whether, on the facts and in the circumstances of the case, the Tribunal was right in upholding the disallowance of the loss of Rs. 1,46,322 for the assessment year 1968-69 and Rs. 27,198 for the assessment year 1969-70 suffered by the assessee on the remittance of its profits from Calcutta to its head office in the U. K. ? (iv) Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the Income-tax Officer was justified in withdrawing the interest of Rs. 14,64,130 granted by him in the original assessment for the assessment year 1968-69 and Rs. 12,09,093 for the assessment year 1969-70 ?"

( 2 ) THE first question is concluded by the decision in the case of the assessee for the earlier year in CIT v. Calcutta Electric Supply Corporation Ltd. Following the said decision, we answer this question in the affirmative and in favour of the Revenue.

( 3 ) THE second question is also concluded against the assessee in view of the decision of this court in the case of Riverside (Bhatpara) Electric Supply Co. Ltd. v. CIT [ 1977] 109 ITR 399. Following the said decision, we answer this question in the affirmative and in favour of the Revenue.

( 4 ) SO far as the third question is concerned, it is also concluded by the decision in the assessee's own case CIT v. Calcutta Electric Supply Corporation Ltd. [1987] 166 ITR 797. Following the said decision, we answer this question in the negative and in favour of the assessee.

( 5 ) WE shall deal with the fourth question separately. The only question which has been referred at the instance of the Commissioner is as follows :"whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the sum of Rs. 6,52,105 for the assessment year 1968-69 and Rs. 8,52,078 for the assessment year 1969-70 being the additional expenses incurred by the assessee due to devaluation of the Indian rupee in redeeming its Sterling debentures was an expenditure wholly and exclusively laid out for the purposes of its business ?"

( 6 ) THIS question is also concluded by the said decision in the case of the assessee Calcutta Electric Supply Corporation. Following the said decision, we answer the question in the negative and in favour of the Revenue.

( 7 ) THE only question that remains to be considered is the fourth question referred to us at the instance of the assessee.

( 8 ) THE facts of the case are stated hereunder :

( 9 ) AT the time of the original assessment for the year 1968-69, the amount of interest payable under Section 214 of the Income-tax Act was Rs. 14,64,130 although at the time of the original assessment, the figure was shown at Rs. 14,61,738. By an order of rectification dated June 28, 1972, the correct interest payable to the assessee under Section 21

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