( 1 ) AT the instance of the Lakshmi Insurance Co. Ltd. , New Delhi, hereinafter referred to as the "assessee company". the Income-Tax Appellate Tribunal has referred the following question for the opinion of this Court:

"whether on the facts and in the circumstances of the case. the Tribunal rightly held that the amount of Rs. 56,028 represented assessee company s income liable to tax ?"

( 2 ) THE said amount was paid to the assessee company by the Central Government in accordance with the provisions of section 7 of the Life Insurance (Emergency Provisions) Act, 1956 in the assessment year 1957-58, the previous year having ended on March, 31, 1957. The assessee company had been carrying on life insurance business up to January 18, 1956. On January 19, 1956, the President of India promulgated the Life Insurance (Emergency Provisions) Ordinance, 1956 (No. I of 1956) which was replaced on March 21, 1956 by the Life Insurance (Emergency Provisions) Act, 1956 (No. IX of 1956 ). The Ordinance and the Act were passed to provide for the taking over, in the public interest, of the management of the life insurance business pending nationalisation thereof. The assessee company