Hegde, J. - (1.) In these appeals by special leave, a common question of law arises for decision and that question relates to the meaning of the word "realization" in S. 5 (o) (ii) of the Expenditure Tax Act, 1957 which will be hereinafter referred to as the "Act". The facts relevant for the purpose of deciding the question of law arising for decision in all the appeals are identical.
(2.) In Civil Appeal No. 2147 of 1969, at the instance of the assessee the Income-tax Appellate Tribunal, Hyderabad Bench, referred the following question to the High Court of Andhra Pradesh: " Whether on the facts and in the circumstances of the case, the expenditure of Rs. 94,500/- incurred by the assessee in London is exempt under S. 5 (o) of the Expenditure Tax Act."
(3.) Similar questions have been referred to the High Court in other appeals.;