( 1 ) IN pursuance of an order passed by this court, the Income-tax Appellate Tribunal, Allahabad bench, has referred the following question of law for the opinion of this court:

"1. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in applying the provisions of Section 271 (1 ) (c) of the Act ? 2. Whether, on the facts and in the circumstances of the case, merely because a revised return and thereafter another revised return was filed by the applicant voluntarily disclosing the profit earned by the applicant amounting to Rs. 61,460 and Rs. 51,810 there was a concealment of income under Section 271 (l) (c) of the Act ? 3. Whether there was any material for the Tribunal to hold that the assessee must have known from the action of the officer in December, 1968, that he is making enquiries about the sale of import licence in M/s. Damo-dar Das and Company ?"

( 2 ) FACTS on which these questions of law have been founded are that penalty proceedings, under section 271 (l) (c) of I. T. Act, were initiated against the assessee, a manufacturer of carpets, maintaining its accounts from Diwali to Diwali, for the non-disclosure of Rs. 61,460, Rs, 50