(1.) THE Tribunal has referred the following questions to this Court for its opinion under S. 18 of the Companies (Profits) Surtax Act 1964 r/w S. 256(1) of the IT Act 1961. The First two of the questions are referred at the instance of the assessee and the remaining two at the instance of the Revenue.
(2.) THE relevant assessment year is asst. year 1974 75.
(3.) THE relevant portion of cl. 3(A) of the debenture trust deed reads as under :