Ajit K.Sengupta, J. - (1.) In this reference under Section 256(1) of the Income-tax Act, 1961, the following questions of law have been referred to this court for the assessment year 1974-75 : "1. Whether, on the facts and in the circumstances of the case and on a proper interpretation of the relevant provisions of the Special Export Promotion Scheme, the receipt of Rs. 1,40,864 arising out of the transfer of import entitlements are capital receipts and not revenue receipts assessable to tax."
(2.) Whether, on the facts and in the circumstances of the case, the Tribunal was justified in holding that the reimbursement of out of pocket expenses amounting to Rs. 21,000 actually incurred by the directors of the assessee-company is an entertainment expenditure which falls within the mischief of Section 37(2A) of the Income-tax Act, 1961, and in so holding whether the Tribunal acted perversely ?
(3.) Whether the Tribunal was justified in upholding the disallowance of reimbursement of expenses amounting to Rs. 21,000 actually incurred by the directors of the assessee-company and in holding that the said reimbursement of expenses was in the nature of entertainment allowance or entertainment expenditure paid by the assessee to any employee or other person within the meaning of Clause (i) of the Explanation to Section 37(2A) of the Income-tax Act, 1961 ?;