P. JAGANMOHAN REDDY, J.

( 1 ) THE question that has been referred to us by the Income-tax Appellate Tribunal is as follows:-"whether on the facts and in the circumstances of the case, the assessee company was entitled to exemption of the sum of Rs. 8,937 under Sec. 4 (3) (i)of the Indian Income-tax Act. "the assessee is a stock exchange company, limited by a guarantee and registered under S. 26 of the Hyderabad Companies Act (Act 4 of 1320f.), which corresponds to S. 26 of the Indian Companies Act, (Act 7 of 1913 ).

( 2 ) THE assessment year with reference to which this question has been postulated is 1961-62 for which the accounting year is the financial year ending 31-3-1961. The company has been assessed to income-tax from 1952-53 onwards. In all the years upto 1960-61, it filed returns of income showing therein the income from interest on securities and it was accordingly assessed. In connection with its assessments for the years 1953-54,1954-55,1955-56 and 1956-57, it made a claim that its income was exempt under the provisions of S. 4 (3) (i)of the Act, which claim was not accepted by the Income-tax Officer or the Appellate Assistant Commissioner or the Tribunal in appeals. T

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