( 1 ) THIS reference arises out of the income-tax assessment of Messrs. Williamson Magor and Co. Ltd. in the assessment year 1964-65, the relevant previous year having ended on the 31st December, 1963. The assessee, inter alia, acts as managing agents, secretaries and/or treasurers of other limited companies and at the material time had been appointed as the secretary of one Tukvar and Co. Ltd. under an agreement dated the 26th July, 1954, which, inter alia, provided as follows : (a) The assessee was appointed as secretary on and from the 1st July, 1954, to continue in such employment for a period of 10 years certain from the said date. (b) The assessee would provide suitable office and establishment for Tukvar and Co. Ltd. , Calcutta. (c) Subject to the provisions of the Companies Act the assessee would in addition to their duties under this agreement perform other duties and work for Tukvar and Co. Ltd. which the directors of the latter may decide and would receive reasonable and proper remuneration therefor as would from time to time be agreed between the parties. (d) The general management of the affairs of Tukvar and Co. Ltd. , viz. , business transactions