( 1 ) AN interesting question of law has been raised in a reference made by the Tribunal under Section 66 (1) of the Indian Income-tax Act, 1922. The question arises out of the order of the Tribunal dated 26-11-1965 for the assessment year 1952- 53 and reads :-

"whether on the facts and in the circumstances of the case, thepayment of Rs. 22,951. 00 to the Vanaspati Manufacturers Association of India is a revenue deduction against the income of the previous year. ?"

( 2 ) THE petitioner which will hereafter be described as the assessee or assessee company, runs a number of mills including a mill for the manufacture of Vanaspati Oil. During the previous year ending 30th June 1951 the Vanaspati Manufacturers Association, Bombay of which the assessee is a member, debited the assessee with a total sum of Rs. 22851. 00. This amount represented the assessee s share of propaganda expenses incurred by the Association. The letter sent by the Association intimatical to the assessee that the expenditure was not on research but on propaganda to counter the agitation against the industry for compulsory colourisation of Vanaspati Oil or for the imposition of a ban on the manufact