R.R. Rastogi, J.

1. MESSRS. Singh Engineering Works, hereinafter referred to as " the assessee ", manufactures iron bars and rods out of ingots manufactured from scrap in its own electric furnace and billets purchased from Hindustan Steel Ltd., Iron and Steel Company and Indian Iron and Steel Company. In its assessments to income-tax for the assessment years 1970-71, 1971-72 and 1972-73, the assessee claimed relief under Section 80-I of the I.T. Act, 1961, hereinafter referred to as " the Act", on its total manufacture. The ITO, on the other hand, allowed relief on the proportionate turnover of iron bars and rods out of ingots manufactured by the assessee itself and not on the turnover of iron bars and rods out of billets purchased by the assessee.

2. BEING aggrieved, the assessee filed revision application under Section 264 of the Act before the CIT, Kanpur-I. The learned CIT by a combined order dated July 3, 1976, upheld the view taken by the ITO. Essentially, he relied upon the assessee's own past history. For the assessment years 1965-66 and 1966-67, similar question had come up in revision application before the CIT (Central), Delhi. A reference was made by the revising