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Issues:
1. Whether the Appellate Tribunal was right in allowing the assessee's claim of loss arising on account of valuation of Government and Trustee Securities as stock-in-trade. Analysis: The reference applications were filed by the CIT, Patiala, seeking the opinion of the High Court on the question of law arising from the Tribunal's order regarding the treatment of the assessee's investments in Government and Trustee Securities as stock-in-trade. The Tribunal's decision was based on the premise that investing in such securities was an essential part of the assessee's banking business, as highlighted in the Privy Council and Supreme Court judgments. The Tribunal concluded that these investments were made in the ordinary course of the assessee's business, necessary for lawful operations under the Banking Regulation Act. The Tribunal emphasized that a reference to the High Court should involve a problematic or debatable question, not an obvious point of law. In this case, the Tribunal's decision was based on factual appreciation and legal precedents, making it unnecessary to refer the matter to the High Court. The Tribunal rejected the revenue's argument to refer to a different Supreme Court judgment, emphasizing that the assessee's securities were akin to stock-in-trade and could be valued as such. The Tribunal held that the assessee's investments were integral to its banking business and did not warrant a different treatment based on the facts of the case. Ultimately, the Tribunal dismissed the reference applications, affirming its decision to allow the assessee's claim of loss on the valuation of Government and Trustee Securities as stock-in-trade. The judgment highlighted the importance of considering the specific facts and legal framework governing the assessee's business activities in determining the appropriate treatment of investments in securities.
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