JUDGMENT
G.G. Sohani, Actg. C.J.
1. For the reasons stated by us in the judgment delivered by us today in M. C. C. No. 120 of 1985 (CIT v. M. P. Audyogik Vikas Nigam Ltd. (No. 1) [1989] 178 ITR 177 (supra)) between the same parties, our answer to the following question referred to this court is in the affirmative and against the Revenue :
“Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the deduction permissible under Section 36(1)(viii) of the Income-tax Act was to be calculated on the assessee’s total income as it stood before the deduction allowable under Section 36(1)(viii)of the Income-tax Act, 1961 ?”
2. In the circumstances of the case, parties shall bear their own costs of this reference.