(1.) Both these are references to this court u/s 66(1) of the Indian I.T. Act, 1922, at the instance of the assessed, The Hindustan Times Ltd., New Delhi. The references arise out of the I.T. assessments of the above company for the assessment years 1961-62 and 1962-63. For the assessment year 1961-62, the following two questions have been referred for the decision of this court:
(2.) Whether, on the facts and in the circumstances of the case, the Tribunal was justified in holding that the sum of Rs. 23,600 is capital expenditure and, as such, could not be allowed? "
(3.) It may be mentioned here that the sum of Rs. 17,771 referred to in the question for assessment year 1962-63 is of the same nature as the expenditure of Rs. 23,600 which is referred to in the second question for the assessment year 1961-62. Thus, one of the two questions is common for both the years. It will be convenient to dispose of both the references by a common judgment.