Heard learned counsel on both sides. Leave granted. Inasmuch as, in our opinion, a referable question of law does arise out of the appellate order of the Tribunal, the Income-tax Appellate Tribunal, Allahabad, is directed to state a case and refer the following question of law for the opinion of the High Court:

"Whether, in the facts and circumstances of the case, the preservation by refrigeration in cold storage of potatoes is a 'process' ordinarily employed by a cultivator within the meaning of sections 2(1)(b)(ii) and 2(1)(b)(iii) of the Income-tax Act, 1961 ?".