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Issues:
1. Deduction of interest on 3% Sterling Promissory Note for specific assessment years. 2. Deduction of interest on 3% Indian Rupee Promissory Note for certain assessment years. 3. Deductibility of interest on 3% Indian Rupee Promissory Note for other assessment years. 4. Deduction of fees paid for representation before the Income-tax Officer for particular assessment years. Analysis: The court addressed four questions referred by the Income-tax Appellate Tribunal. The first two questions pertained to the deduction of interest on 3% Sterling Promissory Note and 3% Indian Rupee Promissory Note for specific assessment years. The Tribunal relied on a previous High Court decision for these questions. The court found that the questions should be answered in favor of the assessee, following the earlier High Court decision, which had also been upheld by the Tribunal. Therefore, the court answered both questions affirmatively in favor of the assessee. Regarding the third and fourth questions, the court refrained from giving an opinion. Citing a Supreme Court decision, the court stated that it would not provide advice on these questions as they were improperly referred and considered incompetent. The court emphasized that it was bound by the Supreme Court's decision, which determined that such questions should not be addressed by the High Court. Hence, questions three and four were left unanswered. It was highlighted that the assessee had not filed reference applications but exercised the right as a respondent to request the Tribunal to refer certain questions. The court acknowledged the importance of jurisdiction in considering such references, as emphasized in the Supreme Court's ruling. Ultimately, the court decided on questions one and two in favor of the assessee based on previous judicial decisions, while questions three and four remained unanswered.
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