1. The short question that requires determination in this reference under Section 66(2) of the Indian Income-tax Act is whether the method of computation adopted by the Tribunal is correct or the one adopted by the assessee is correct. The method adopted by the Tribunal is as follows : "According to Section 17(4), Clause (a), the super-tax payable by the assessee would be the super-tax which would have been payable on his total income, viz., Rs. 77,295 as reduced by the amount of income brought into British India out of the past State profits, viz., Rs. 27,229 (CC), i.e., the super-tax on Rs. 50,066 (AA + BB) which amounts to Rs. 3,762-6-0 multiplied by the fraction 77295/50066. The super-tax payable by the,assessee, applying the provisions of Section 17(4) alone would, therefore, be Rs. 5,859. But the total income of the assessee in this case also included Rs. 27,436 (BB), income which accrued to the assessee in Indian States during the relevant assessment year and exempt from income-tax or super-tax according to Section 14(2)(c). Therefore, applying the provisions of Section 17(3), the super-tax payable by the assessee would be further reduced as follows:

Rs. 5,859 (being