J.V.Gupta, J.

1. In this reference, arising out of the assessees applications under Section 256(1) of the Income-tax Act, 1961 (hereinafter referred to as " the Act "), the following two questions of law have been referred to this court :

" (i) (a) Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in holding that the subsidy of Rs. 11,969 received by the assessee from the Government constituted a revenue receipt to be taxed as such (assessment year 1965-66) ?

(b) Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in holding that the subsidy of Rs. 12,815 received by the assessee from the Government constituted a revenue receipt to be taxed as such (assessment year 1967-68) ?

(ii) Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in holding that the amount of Rs. 6,104 representing admission fee charged by the assessee-co-operative society from its members constituted a taxable receipt ? "

2. The facts giving rise to these questions of law are : The assessee is a co-oporative society registered under the Co-operative Societies Act, which is running a store o