JUDGMENT

SABYASACHI MUKHARJI, J.:— These two appeals arise by certificate by the High Court in Income-tax References Nos. 32 and 33 of 1971. The High Court of Kerala by its judgment dated 19th July, 1973 answered the following two questions in the negative and in favour of the revenue:

"(i) Whether, on the facts and in the circumstances of the case, the Tribunal was justified in law in holding that the sums of Rs. 2,90,220 and Rs. 3,63,750 were not assessable as income of the assessee for the assessment years 1960-61 and 1961-62?

(ii) Whether, on the facts and in the circumstances of the case, the Tribunal was justified in law and had material for holding that the sums of Rs. 2,90,220 and Rs. 3,63,750 are exempt from taxation under S. 4(3)(vii) of the Indian Income-tax Act, 1922 for the assessment years 1960-61 and 1961-62 respectively?"

2. The references relate to assessment years 1960-61 and 1961-62. The assessees accounting year was the calendar year. The assessee publishes a Malyalam daily newspaper by name Kerala Dhwani. Till 1953, he was a lecturer in History and Political Science in the College at Kottayam. He had his education in the United States of America, during 1953 to 19