( 1 ) THESE four reference applications under Section 256 (1) of the Income-tax Act, 1961 (in short act ) relate to assessment years 1972-73 and 1973-74. While two of the reference applications have been tiled hut the Revenue, two others have been filed by the assessee. Following question "has been referred, at the instance of Revenue, for opinion of this Court by the Income-tax Appellate Tribunal Delhi Bench-C Delhi (in short Tribunal ):-

"whether on the facts and in the circumstances of the case, the Tribunal is correct in holding that the dividend income from the bonus shares of mmlsr (P) Ltd. held by the assessee was exempted under Section 11 for the assessment years 1972-73 and 1973-74?"so far as the assessee s reference are concerned, following questions have been referred:

" (I) Whether the Tribunal was correct in holding that the eight persons who subscribed their names to the memorandum of association of the assessee society could be regarded as "founders" of an "institution" viz. , the assessee society, for the purposes the Section 13 (3) (a) of the Income-tax Act, 1961, for the assessment years 1972-73 and 1973-74? (2) Whether on the facts and in the circums