1. By this reference under S.256(1) of the Income - tax Act , 1961 ("the Act"), the Income - tax Appellate Tribunal has referred the following question of law to this court for opinion at the instance of the Revenue:
"Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in holding that the claim of development rebate on the cost of meters installed by the assessee - company at the residential or office premises of its consumers, was not at variance with the provisions of S.33(6) of the Act?"

2. The assessee is an electric supply undertaking and its business is to supply electrical energy to its consumers. For the assessment year 1974-75, the Income - tax Officer determined the development rebate admissible to the assessee at Rs. 8,01,917 and allowed Rs. 5,59,744 against the total income available for the purpose. The development rebate determined by the Income - tax Officer included a sum of Rs. 61,155 relatable to the cost of meters installed by the assessee - company at the residential or office premises of its consumers. However, the order of the Income - tax Officer was revised by the Commissioner of Income - tax ("the Commissioner") under S.