1. IN this reference under section 66 (2) of the Indian Income Tax Act, 1922 the following question has been referred to this court:

"whether, on the facts and in the circumstances of the case the electrolysis plant set up by the assessee company was a new industrial undertaking within the meaning of Section 15c of the Indian income-tax Act, 1922 and as such the necessary relief under that Section was admissible to the assessee "

2. THE reference arises in respect of the assessment year 1959-60. The assessee company owns a paper mill and manufactures paper and sells it in the market. In the previous year relevant to the present assessment year it had set up an electrolysis plant for the purpose of manufacturing caustic soda which is an essential chemical for use in the process of manufacture of paper. The assessee company obtained a separate licence for the manufacture of caustic soda and the plant was housed in a separate building. In assessing the company for the relevant year the income Tax Officer held that the plant was ancillary to the main manufacturing unit and was not, therefore, a new industrial undertaking as contemplated under Section 15c of the Indian Income tax