Deb, J. - (1.) The following questions are involved in this reference under Section 66(1) of the Indian Income-tax Act, 1922 : "1. Whether, on the facts and in the circumstances of the case, the objects of the assessee-association were objects of general public utility and accordingly the assessee was entitled to exemption from tax in respect of all its activities under Section 4(3)(i) of the Indian Income-tax Act, 1922.
(2.) Whether, on the facts and in the circumstances of the case, income derived by the assessee from (a) membership roster advertisement, (b) member roster sale fees, (c) agents' authorisation fees, and (d) miscellaneous receipt, was income from business carried on in the course of the actual carrying out of a primary purpose of the assessee ?
(3.) If the answer to question No. 2 above is in the affirmative, whether the work in connection with the business was mainly carried on by beneficiaries of the assessee and accordingly the income derived from such activities was exempt from tax under Section 4(3)(i) of the Income-tax Act, 1961?" 2. The statement of the case relates to the assessment years 1961-62 to 1964-65. The assessee is a company and was registered under Section 26 of the Indian Companies Act, 1913, as an association not for profit and was qualified for and exempted from using the word "limited" in its name. The assessee claimed exemption under Section 4(3)(i) of the Indian Income-tax Act, 1922, for the assessment year 1961-62 and under the corresponding Section 11 of the Income-tax Act, 1961, for the remaining three assessment years. 3. We reframe question No. 1 by adding the words "for the assessment year 1961-62 and the corresponding Section 11 of the Income-tax Act, ] 961, for the assessment years 1962-63 to 1964-65" after the words "Indian Income-tax Act, 1922.";