SABYASACHI MUKHARJI, J.

( 1 ) IN this reference under Section 256 (2) of tbe I. T. Act, 1961, as directed by this court, the Tribunal has referred the following three questions for the assessment year 1967-68 :"1. Whether, on the facts and in the circumstances of the case, the findings of the Tribunal as to the nature, object and purpose of the fund of the assessee held in the U. K. in Pound Sterling were based on no evidence and/or were perverse ? 2. Vhether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the profit arose in respect of the amount of 1,796 which was not remitted in India ? 3. Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the sum of Rs. 1,68,157 had been eorrectly taxed as part of the assessec's trading profits?"

( 2 ) IN order to appreciate these questions, it will be necessary to refer to certain facts as mentioned in the statement of case. But we will refer to certain summary of facts, because there is some suggestion by learned advocate for the assessee that the statement of case does not correctly summarise all the essential ingredients of the findings or of the fac

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