M.C. Agarwal, J.

1. THESE are references by the Income-tax Appellate Tribunal, Allahabad, made under Section 256(1) of the Income-tax Act, 1961.

2. IN Income-tax Reference No. 100 of 1982, the Tribunal has referred the following questions stated to be of law and to arise out of its order dated October 31, 1980, passed in ITA No. 1532 (Alld.) of 1975-76 for the assessment year 1964-65 :

"1. Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was justified in law in holding that the Income-tax Officer was justified in initiating reassessment proceedings under Section 147(a) of the Income-tax Act, 1961 ?

2. Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was justified in law in restoring the matter to the Appellate Assistant Commissioner to decide on merits the question of includibility of the remuneration payable to the assessee for the assessment year 1964-65 as a trustee of the Sherwani Charitable Trust ?"

In Income-tax Reference No. 285 of 1981, the following questions arising out of the Tribunal's order dated December 12, 1980, in ITA Nos. 1864, 1865 and 1866 of Allahabad of 1979 for