JUDGMENT

 This ap

eal is preferred against the judgment of the Gauhati High Court answering the question referred to it against the assessee. The question referred is :

"Whether on the facts and in the circumstances of the case, the assessee i.e., Assam Co-operative Apex Marketing Society Ltd., is entitled to exemption under S. 8 1 (1)(c) in respect of their income arising out of procurement of paddy and other agriculture produce?"

2. The assessment year concerned herein is 1962-63, the first assessment year under the Income-tax Act, 1961. During the accounting year relevant to the said assessment year, the appellant. The Assam Co-operative Apex Marketing Society Ltd., Assam was appointed as the procuring agent for paddy by the Government under a scheme evolved by the Government of Assam and contained in its proceeding dated 23rd November, 1962. The assessee is a society registered under the Assam Co-operative Societies Act, 1949. The objects of the Society are:

" (i) to arrange for the sale of produce of the members of affiliated societies and other members to the best advantage.

(ii) to purchase and sell agricultural produce and farm and farmers requisites including seeds, manures, fe