ORDER : It is represented that the dispute is covered by the judgment of this Court in Escorts Ltd. v. Union of India, (1993) 1 SCC 249 : (1993) 199 ITR 43 . The matter is decided in favour of the Revenue. Consequently, these appeals have to be allowed. As a result thereof the judgment of the High Court in WP No. 1236 of 1980 is set aside and the writ petition stands dismissed. Further, the said reference answered by the High Court in Commissioner Income Tax v. Hico Products (P) Ltd., (1991) 187 ITR 517 (Bom) in favour of the assessee is erroneous and the said reference is answered in favour of the Revenue. The appeals are allowed in the above terms. No costs. Appeals allowed.