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1. At the instance of the Revenue, the Income-tax Appellate Tribunal, Amritsar, has referred the following two questions for the opinion of this court with regard to the assessment year 1970-71 concerning Prithipal Singh and Co., Ludhiana :

"(1) Whether, on the facts and in the circumstances of the case, the Appellate Tribunal is right in law in holding :
(a) that the provisions of the Explanation to Section 271(1)(c) will not be attracted to the present case ?
(b) that the word 'income' occurring in Clauses (c) and (iii) of Section 271(1) refers to a positive income only and not to a loss ?