AJIT K. SENGUPTA, J.

( 1 ) THERE are two consolidated references for the assessment year 1984-85 made by the Tribunal under Section 256 (1) of the Income-tax Act, 1961, one at the instance of the assessee and the other at the instance of the Revenue. At the instance of the Revenue, the following question of law has been referred to this court :"whether, on the facts and in the circumstances of the case, the Tribunal was justified in holding that the sum of Rs. 4 lakhs payable as premium is allowable revenue expenditure over a period of seven years and, therefore, for the assessment year 1984-85, one-seventh of the sum of Rs. 4 lakhs should be allowed as a deduction ?"

( 2 ) THE following questions of law have been referred at the instance of the assessee :"1. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in holding that the assessee was entitled to a deduction of Rs. 57,643 only and not of the entire amount of Rs. 4 lakhs being premium payable on debentures in computation of its income for the assessment year 1984-85 ?2. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in holding that the expenditure of

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