- (1.) These two references made to this court in terms of Section 256(2) of the Income-tax Act, 1961, relate to the assessment years 1983-84, 1984-85, 1985-86 and 1986-87.
(2.) Although two questions each for the aforementioned assessment years were referred to this court, but two questions being question No. 2 for the assessment years 1983-84 and 1984-85 were not pressed and the same are as follows : "1. Whether,, on the facts and in the circumstances of the case, the Tribunal was justified in confirming the addition of Rs. 1,15,000 in respect of the alleged extra income earned from sales at Ahmedabad ? 2. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in confirming the addition of Rs. 1,35,627 in respect of the alleged extra income earned from the sales at Ahmedabad ?"
(3.) One of the questions, for each of the assessment years is common which is question No. 2 as mentioned hereinbelow. This court, therefore, is required to answer the following four questions : "1. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in confirming the disallowance of Rs. 1,07,570 ? 2. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in holding that the transport subsidy granted under the Transport Subsidy Scheme, 1971, amounting to Rs. 3,26,912 was a revenue receipt ? 3. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in holding that the expenditure of Rs. 87,249 was in the nature of entertainment expenditure as per Explanation 2 to Section 37(2A) of the Income-tax Act, 1961 ?;