( 1 ) IN the background of certain rather interesting facts, we are asked to answer the following questions referred to us in this reference under Section 27 (1) of the W. T. Act, 1957 :"1. Whether, on the facts and in the circumstances of the case, in view of the probate of the will having been granted by the High Court, it was competent for the Tribunal to go into the question as to the genuineness of the will of the deceased, Satyanarayan Agarwalla, dated October 11, 1956 ?

( 2 ) WHETHER, on the facts and in the circumstances of the case, the Tribunal, in view of Section 273 of the Indian Succession Act, 1925, was justified in law in holding that the said will executed by late Satyanarayan Agarwalla proved and registered in the High Court at Calcutta in the course of probate proceedings being Matter No. 156 of 1976 was not a genuine will ?

( 3 ) WHETHER, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was justified in law in confirming the penalties of Rs. 1,716 (assessment year 1962-63), Rs. 309 (assessment year 1963-64), Rs. 265 (assessment year 1964-65), Rs. 442 (assessment year 1965-66), Rs. 427 (assessment year 1