1979 (1) TMI 3

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..... s in these two cases are different, the questions referred for the opinion of this court are identical. Therefore, it is enough to consider the questions referred in T.C. No. 211 of 1975 only. It may be mentioned here that in T.C. No. 211 of 1975, the assessment years relevant are 1963-64 and 1964-65 and in T.C. No. 262 of 1975, the assessment years are 1963-64 and 1965-66. The questions in T.C. .....

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..... o be answered in the affirmative and in favour of the assessees. As far as question No. 2 is concerned, that was not the subject of consideration by the Tribunal and had not been raised at any stage. As the matter had not been considered by the Tribunal itself, we do not think that this question can be said to arise out of the Tribunal's order. Therefore, we return the reference as far as this qu .....

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