SABYASACHI MUKHARJI, J.

( 1 ) IN this case under Section 256 (1) of the I. T. Act, 1961, the following question has been referred to this court:"whether, on the facts and in the circumstances of the case, the Tribunal has misdirected itself in law in holding that the business carried on by the assessee in galvanizing metal on behalf of the customers was an industrial undertaking engaged in manufacture and production of articles within the meaning of Section 84 of the Income-tax Act, 1961, and as such the assessee was entitled to relief under Section 84 of the said Act for the assessment year 1965-66 in respect of profits derived from such business ?"

( 2 ) THE assessment year involved is 1965-66 and the previous year ended on March 31, 1965. The assessee is a private limited company. During the year the assessee-company carried on the business of manufacturing and sale of metals and also in galvanizing work for outsiders. The assessee claimed exemption of tax under Section 84 in respect of business of manufacturing and sale of metals and its galvanizing work. The ITO held that the assessee was not entitled to relief under Section 84 in respect of trading in raw materials from whic

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