R.R. Rastogi, J.

1. THIS is a reference under Section 256(2) of the I.T. Act, 1961 (hereinafter referred to as "the Act"). The following two questions have been referred by the Income-tax Appellate Tribunal, Allahabad Bench, for the opinion of this court:

"1. Whether, on the facts and in the circumstances of the case, the liability in respect of the sum of Rs. 18,533 paid to Ahmedabad Textile Industry Research Association accrued in the previous year relevant to the assessment year 1960-61 ?

2. Whether the finding of the Appellate Tribunal in respect of the addition of Rs. 6,81,643 to the book results of the Pondicherry Unit stands vitiated because it does -not take into account some relevant material and takes into account some irrelevant material and considerations ? "

2. THE brief facts are that the assessee, a public limited company, is carrying on the business of manufacture of cotton yarn and cloth. It has got several units including one at Kanpur and another at Pondicherry. Its head office is at Kanpur. It follows the calendar year as its year of account. In its assessment for the assessment year 1960-61, the assessee in its head office account claimed a deduction of Rs