1 These references arise out of assessment proceedings against the Travancore Sugars and Chemicals Ltd., hereinafter referred to as the assessee for the assessment years 1959-60 to 1962-63 and have been made by the Income Tax Appellate Tribunal, Cochin Bench under S.66(i) of the Indian Income Tax Act, 1922 and S.256(i) of the Income Tax Act, 1961, at the instance of the Commissioner of Income Tax, Kerala, Ernakulam. The questions referred to this Court are:
"(1) Whether on the facts and in the circumstances of the case, the payment of Rs. 1,45,969/- by the assessee to the Kerala Government under the agreements dated 18-6-1937 and 28-1-1947, was allowable under S.10 of the Indian Income Tax Act, 1922.
(2) Whether on the facts and in the circumstances of the case, the payment of Rs. 1,14,520/- by the assessee to the Kerala Government under the agreements dated 18-6-1937 and 28-1-1947, was allowable under S.10 of the Indian Income Tax Act, 1922.
(3) Whether on the facts and in the circumstances of the case, the payment of Rs. 1,21,578/- by the assessee to the Kerala Government under the agreements dated 18-6-1937 and 28-1-1947, was allowable under S.10 of the Indian Income Tax Act, 1922