Sabyasachi Mukharji, J.—These appeals by certificate granted by the High Court of Allahabad under section 66A(2) of the Indian I.T. Act, 1922, arise out of the judgment delivered and order passed on 3rd January, 1973, by the High Court of Allahabad in Income-tax Reference No. 450 of 1965. The following question of law had been referred to the High Court