Judgment

HEGDE, J.:- These are connected appeals by certificates. They relate to respondent s assessment for the assessment years 1954-55, 1955-56 and 1956-57. The previous financial years are the relevant accounting years.

2. In all these appeals, as directed by the High Court of Calcutta under Section 66 (2) of the Indian Income Tax Act, 1922, certain questions were submitted by the Tribunal. In the first case i.e. Civil Appeal No. 242 of 1970 only one question was submitted and in the other two cases i.e. Civil Appeals Nos. 243 & 244 of 1970, two questions were submitted. The question submitted in the first case is as follows:

"Whether on the facts and in the circumstances of the case the sum of Rs. 1,11,779 said to have been foregone by the assessee as Managing Agency commission was allowable as a revenue expenditure under S. 10 (2) (xv) of the Indian Income-tax Act, 1922 for the assessment year 1954-55"?

3. Similar questions were called for the remaining two assessment years as well. But, in addition, one more question, namely:

"Whether on the facts and in the circumstances of the case the sum of Rs. 30,000 said to have been foregone by the assessee as office allowance receivable f