Harnam Singh, J.

1. This order disposes of Income-tax Cases Nos. 18 to 22 of 1951.

2. By 66-Reference Applications Nos. 1141 to 1145 of 1950-51, the Punjab Distilling Industries Ltd., Khasa, hereinafter referred to as the assessee, applied to the Income-tax Appellate Tribunal under Section 66, Income-tax Act, 1922, hereinafter referred to as the Act, requiring the Appellate Tribunal to state and to refer the cases to the High Court on two questions of law. In the several applications the questions of law arising out of the orders of the Tribunal were stated to be as under :

(1) Whether, on the facts and circumstances of the case, the security deposit received for the purpose of ensuring the return of empty bottles was income assessable under Section 10, Income-tax Act?

(2) Whether, on the facts and circumstances of the case, cash lying with the assessee in the form of security deposit, could, on the return of bottles, be treated as stock-in-trade without the price o£ bottles being separately paid under the buy-back system?

(3) In rejecting the applications the Tribunal found that out of the orders of the Tribunal in the several cases no question of law arose.

3. In these ci