JUDGMENT B.P. Jeevan Reddy, CJ. 1. Under Section 256(1) of the Income-tax Act, 1961, the following question is referred : "Whether the Tribunal was correct in holding that the loans taken by the assessee had to be deducted while computing its capital for working out the relief due to it under Section 80 J of the Income-tax Act, 1961 ? " 2. It is agreed by counsel for both the parties that, following the decision of the Supreme Court in Lohia Machines Ltd. v. Union of India [ 1985] 152 ITR 308, this question must be answered in the negative (sic.), i.e., in favour of the Revenue and against the assessee. The income-tax reference is answered accordingly.