1. The Income-tax Appellate Tribunal, Chandigarh Bench, has referred the following question of law for our opinion :

" Whether, on the facts and in the circumstances of the case, the Appellate Tribunal was right in holding that the firm was entitled to registration under Section 185 of the Income-tax Act, 1961 ? "

2. A firm known and styled as Messrs. Gian Chand & Co., having five partners, obtained a licence in their separate names from the Fisheries Department of the Punjab Government for fishing in the public waters. They took another four persons as partners in the same firm. Thus, the firm came to be constituted of nine partners. The Income-tax Officer while looking into the claim for registration went into the past history of the case and in view of the frequent changes in the constitution of the firm took the view that these changes had been employed in order to reduce the incidence of taxation. This is the only basis on which he refused registration on the ground that the firm was not genuine. The assessee preferred an appeal to the Appellate Assistant Commissioner. The said Commissioner remanded the case to the Income-tax Officer for some other enquiries. On receip