R.N.Pyne, J. - (1.) In this reference under Section 256(1) of the Income-tax Act, 1961, the following question of law said to arise out of the Tribunal's order dated February 27, 1970, has been referred for this court's opinion : "Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the income of the assessee-association derived from the business of export of sugar and interest from current and fixed deposits were exempt from tax subject to verification by the Appellate Assistant Commissioner of the facts with reference to the provisions of section 11(1)(a) of the Income-tax Act, 1961 ?"
(2.) This reference relates to the assessment year 1965-66, the relevant previous year being the calendar year 1964.
(3.) The controversy in this reference is whether the income derived by the assessee-association from the business of export of sugar and interest from current and fixed deposits is exempt from income-tax under section 11(1)(a) of the Act.;