ORDER

1. These appeals, by special leave, are directed against the judgment of the Allahabad High Court whereby the following question which was referred to it for opinion by the Income Tax Appellate Tribunal (hereinafter referred to as "the Tribunal") has been answered against the assessee and in favour of the Revenue : "Whether on the facts and in the circumstances of the case, the assessee was entitled to exemption under Section 80-P (2) (a) (i) of the Income Tax Act, 1961 from income from press and income from supply of pumping sets ?" a

2. These appeals relate to the Assessment Years 1971-72 and 1972-73. The U.P. Cooperative Cane Unions Federation Ltd. (hereinafter referred to as "the Federation") is a cooperative society registered under the U.P. Cooperative Societies Act, 1965 (hereinafter referred to as "the Cooperative Societies Act"). The members of the Federation are cane unions which are also cooperative societies and the members of these cane unions are the individual cane-growers. No individual cane-grower is a member of the Federation. The Federation had sponsored an irrigation scheme for small farmers whereunder loan applications of the cane-growers were forwarded t