( 1 ) IN this reference under Section 66 (2) of the Indian Income-tax Act, 1922, the following question has been referred to this court:" Whether, on the facts found by the Tribunal or on record and in the circumstances of the case, the Tribunal was justified in holding that Section 15c of the Indian Income-tax Act, 1922, was applicable to the new production units added to the existing production units of the assessee at Belur, Alupuram and Muri in respect of buildings, plants and machineries and directing exemption to be granted under the aforesaid section accordingly ? "

( 2 ) THE relevant assessment year is 1960-61, the corresponding previous year being the calendar year ended on December 31, 1959. The assessee-company is a manufacturer of aluminium ingots from ores. In the earlier years it had four manufacturing centres at Belur, Kalwa, Alupuram, and Hirakud. In the present accounting year one more was added at Muri and also there were additional extensions to the existing factories at Belur and Alupuram. In connection with the assessment year 1960-61 the assessee-company had claimed relief under Section 15c before the Income-tax Officer in respect of fresh capital o