(1.) In this reference under Section 256(2) of the I.T. Act, 1961, the following questions have been referred to this court,
(2.) Whether the finding of the Tribunal that the assessee entered the business of manufactures and exports of aluminium goods with the clear intention of taking advantage of such Special Export Promotion Scheme is based on any material or evidence and is perverse ?
(3.) Whether the finding of the Tribunal that the profits and gains from the sale proceeds of import entitlements were foreseen by the assessee at the time of making exports and, therefore, were earned by the assessee in the ordinary course of its business is based upon any material or evidence and is perverse ? "