Kapur, J. - (1.) This is a reference made by the Income-tax Appellate Tribunal referring the following question to this Court: "Where a co-operative bank deals in sugar and standard cloth with special permission of the authorities and earns income from such activities, is such income exempt from tax under Item No. 2 of the Government of India Notification F.D. (C.R.) Notification R. Dua. No. 291-1. T/25, dated 25-8-1925, as subsequently amended (Income-tax Manual, 10th Edition, Part II, pages 257-258)?"
(2.) The assessee, the Hoshiarpur Central Co-operative Bank, Limited, Hoshiarpur, was registered: under Section 9, Co-operative Societies Act, and the objects as mentioned in the bye-laws are: "1. The carrying on of banking and credit business; 2. The purchase and sale for common account of agricultural implements and produce;
(3.) The supervision and audit of registered co-operative societies;;