- (1.) The Income-tax Appellate Tribunal, Allahabad, has referred the following questions of law under Section 256(1) of the Income-tax Act, 1961, hereinafter referred to as "the Act", for opinion to this Court : 1. Whether, on the facts and in the circumstances of the case, the Tribunal was correct in law in holding that the incentive bonus paid to the Development Officer of Life Insurance Corporation of India is not chargeable to tax under the head 'Salary' ?
(2.) Whether, on the facts and in the circumstances of the case, the Tribunal was correct in law in holding that the incentive bonus earned by the Development Officers of LIC is business income and expenditure incurred in earning incentive bonus is an allowable deduction ? 2. The present reference relates to the assessment years 1984-85 and 1985-86.
(3.) Briefly stated the facts giving rise to the present reference are as follows :;