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....erence has been directed by the High Court on the application of the revenue under s. 256(2) of the I.T. Act, 1961. So far as the first question is concerned, it is undoubtedly a question of law and could properly form the subject-matter of a reference but the second question as framed is clearly a question of fact and we fail to see how it could be directed to be referred by the High Court. The q....