( 1 ) THIS income-tax reference under Section 66 (1) of the Indian Income-tax Act, 1922, refers the three following questions for determination by the court. The questions are :" (1) Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the steel foundry division was an industrial undertaking to which Section 15c of the Indian Income-tax Act, 1922, applied? (2) Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the jute mill division set up by the assessee-company was an industrial undertaking to which Section 15c of the Indian Income-tax Act, 1922, applied? (3) Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the claim for deduction of wealth-tax paid during the accounting year was admissible in computing the assessee's profits from its business ?"

( 2 ) WE can straightaway dispose of the third question as we find it is already covered by the decision in Travancore Titanium Products Ltd. v. Commissioner of Income-tax, where the Supreme Court held that the amount of wealth-tax paid by an assessee on his net wealth under