Sabyasachi Mukharji, J. - (1.) In this reference under Sub-section (2) of Section 256 of the I.T. Act, 1961, as directed by this court, for the assessment years 1961-62 to 1967-68 the following questions have been referred to us : For the years 1961-62 to 1967-68 "1. Whether, on the facts and in the circumstances of the case, the proceedings initiated under Section 147(a) of the Income-tax Act, 1961, were valid and legal ?
(2.) Whether, on the facts and in the circumstances of the case, the Tribunal was justified in holding that there was no relationship of employer and employee between the assessee-company and Shri A.V. Birla, Smt. Priyamvada Devi Birla and Smt. Sunanda Devi Birla :
(3.) Whether, on the facts and in the circumstances of the case, the Tribunal was justified in holding that the remuneration paid to Shri A.V. Birla, Smt. Sunanda Devi Birla and Smt. Priyamvada Devi Birla were not incidental to the business and could not be allowed as business expenditure ?;