1. The Income-tax Appellate Tribunal, Delhi Bench "C", has referred the following questions of law to this court for opinion along with the statement of the case:

"1. Whether, on the facts and circumstances of the case, distribution of assets among the partners in species on the dissolution of the firm amounts to sale or transfer within the meaning of section 10(2) (vib) of the Indian Income-tax Act, 1922/section 34(3) (b) of the Income-tax Act, 1961 ?

2. Whether, in view of the provisions of section 10(2) (vic) (ii) of the Indian Income-tax Act, 1922/section 33(4) of the Income-tax Act, 1961, on the admitted facts and in the circumstances of the case, one-half of the development rebate in respect of machinery and plant which fell to the share of the two partners, A. R. Khosla and Adarsh Bala Khanna, was rightly withdrawn by the Income-tax officer in respect of the assessment years 1959-60 to 1963-64 ?

3. Whether, in respect of the assessment year 1964-65 when the factory worked for the whole year, the Income-tax Officer was legally entitled to disallow development rebate for the year in question on the basis of subsequent events which took place after the close of the acco