-1_ IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX REFERENCE NO. 228 of 1994 The Commissioner of Income-Tax, Mumbai City I, Mumbai : Appellant v/s M/s. Tata Engineering & Locomotive Co.Ltd. : Respondents Mr. P.S. Sahadevan Advocate for appellant Mr. P.C. Tripathi with Mr. Dinesh Vyas sr.advocate for respondents Coram : Dr.S. Radhakrishnan S.J. Kathawalla, JJ. Date: 23.7.2008 P.C. . Heard learned counsel for the appellant and the learned counsel for the respondents. The learned counsel for the appellant and the learned counsel for the respondents categorically state that the queston of law referred to in the above reference is squarely covered against revenue in the case of (196 ITR page 149) Commisioner of Income Tax vs Gwalior Rayon Silk Manufacturing Co. ltd. Hence the question of law referred to in the above is answered in favour of the assessee and against the revenue. (S.J. Kathawalla,J.) (Dr.S. Radhakrishnan,J.)