ORDER : After hearing learned counsel for the appellant, we find that the precise question raised in the present appeal is squarely covered by the decision of this court in Ahmed Ibrahim Sahigra Dhoraji v. CWT, [1981] 129 ITR 314 (SC) wherein the impugned judgment of the Allahabad High Court was also approved. In this view, the appeals fail and are, accordingly, dismissed ; but there will be no order as to costs.