( 1 ) THIS appeal against the judgment of the learned single judge of this court passed on July 16, 1990, has been filed by Brooke Bond Lipton India Ltd. , an existing public company incorporated under the Companies Act, 1956, and having its registered office at Brooke House, Calcutta.

( 2 ) TEA Estates India Limited was a company in existence prior to the year 1993, and was engaged in the business of growing green tea leaves in its tea gardens and manufacturing black tea and selling the same in the market. The method of accounting of the said company was mercantile and the accounting period of this was the financial year. This company was a regular income-tax assesses under the Income-tax Act, 1961, and was being assessed by the Income-tax Department, Sector-10, Calcutta, for all the relevant assessment years including the assessment year 1993-94. It is claimed that in computing the taxable income, Tea Estates India Limited was entitled to benefits under the provisions of Section 32ab and Section 33ab of the Income-tax Act, apart from other benefits and reliefs allowable thereunder. It is further claimed that in the assessment years 1987-88, 1988-89, 1989-90 and