N.K.Agrawal, J.

1. This order will dispose of Income-tax References Nos. 47 and 48 of 1983 and Income-tax References Nos. 96 to 99 of 1982, as common questions of law and facts are involved therein.

2. The questions of law referred to this court for opinion by the assessee as well as the Commissioner of Income-tax for the assessment years 1975-76, 1976-77 and 1977-78 are as under :

Questions of law referred at the instance of the assessee : For the assessment year 1975-76 : "1. Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was right in law in holding that the additional grounds taken for the first time before the Tribunal, in respect of claiming the value of entitlements to import against the export as capital receipt immune from taxation, cannot be admitted ?

2. Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was right in law in holding that the provisions of Section 144B of the Income-tax Act, 1961, introduced with effect from January 1, 1976, have rightly been applied and the assessment made was not barred by limitation ?

3. Whether, on the facts and in the circumstances of the