AJIT K. SENGUPTA, J.

( 1 ) IN this reference under Section 256 (2) of the Income-tax Act, 1961, the Tribunal has prepared the statement of case with the following questions of law relating to the assessment years 1981-82 and 1982-83 :"1. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in holding that part of the interest amounting to Rs. 1,87,618 paid on moneys borrowed to advance loans amounting to Rs. 42,08,459 and Rs. 3,55,021 to Messrs. East India Electricals and Messrs. New India Electricals (Cal) Pvt. Ltd. should be disallowed ? whether the Tribunal was justified in holding that the interest payable by the assessee to its creditors and the interest received by him from his debtors were not interrelated so as to justify the exclusion of interest payable by him on the ground of non-receipt of interest receivable by him ? whether the Tribunal was justified in holding that the nature of income receivable from the advance made was not material in deciding the issue of the admissibility of interest on monies borrowed to support the above advances"

( 2 ) THE additional question of law for the assessment year 1981-82 is as follows :"whether the

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