JUDGMENT Hegde, J.—This is a reference under section 66(2) of the Indian Income Tax Act, 1922, to be hereinafter referred to as the "Act". It was made on the direction given by this court in C. P. No. 258 of 1962 on the file of this court. The reference in question was called for at the instance of the Commissioner of Income Tax Mysore, at Bangalore. The question referred for the opinion of this court is :