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....ough the assessees in these two cases are different, the questions referred for the opinion of this court are identical. Therefore, it is enough to consider the questions referred in T.C. No. 211 of 1975 only. It may be mentioned here that in T.C. No. 211 of 1975, the assessment years relevant are 1963-64 and 1964-65 and in T.C. No. 262 of 1975, the assessment years are 1963-64 and 1965-66. ....