Rajendra Nath Mittal, J.

1. This judgment will dispose of Income-tax Reference Cases Nos. 67 to 71 of 1977. The references have been made under Section 256(1) of the I.T. Act, 1961, by the Income-tax Appellate Tribunal, Chandigarhi for opinion of this court.

2. The facts are that the five references are in respect of four assessment years, that is, from 1968-69 to 1971-72. These arise out of the consolidated order passed by the Income-tax Appellate Tribunal, Chandigarh Bench (hereinafter referred to as "the Tribunal"), in eight cross-appeals, four by the Revenue (namely, I.T.A. Nos. 323 to 326) and four by the assessee (namely, I.T.A. Nos. 336 to 339) of 1974-75. The Revenue withdrew three of its appeals, namely, I.T.A. Nos. 323 to 325 relating to the assessment years 1968-69 to 1970-71, respectively. The fourth appeal of the Revenue (namely, I.T.A. No. 326) for the assessment year 1971-72 was accepted. All the four appeals filed by the assessee were dismissed. The assessee filed five reference applications, four from the appeals filed by it, namely (R.A. No. 143 to 145 and 142 of 1976-77), and the fifth (namely, R.A. No. 146 of 1976-77) from the appeal filed by the Revenue