( 1 ) IN this reference under Section 256 (1) of the I. T. Act, 1961, we are concerned with four assessment years, namely, assessment years 1966-67 to 1969-70 and the relevent accounting years are Diwali years 2022 to 2025 respectively.

( 2 ) THE assessee is a private limited company. By a lease dated the 21st September, 1954, entered into between the assessee and one Maharaja Probirendra Mohau Tagore, the latter gave on lease, "all these messuages, lands, hereditaments and premises No. 26, Prosanna Kumar Tagore Street, commonly known as ' Tagore Castle' in the town of Calcutta" to the assessee for a period of 84 years with an option of renewal for a further period of 7 years. In order to appreciate the contentions urged in this case, it would be necessary to set out in extenso the relevant clauses of the said lease dated the 21st September, 1954. In the recital clause it was stated, inter alia, as follows :"and Whereas the Lessee has agreed to take a lease for the said period of 84 years of the said messuages, tenements or dwelling houses, land, hereditaments and premises No. 26, Prosonno Coomar Tagore Street, commonly known as 'tagore Castle' together wi