Two questions out of six re ferred by the Income Tax Appellate Tribunal, Allahabad, survive for consideration in this appeal and these are: (1) Whether on the facts and in the circumstances of the case, and on a true interpretation of the agreement, the Tribunal erred in holding that the sum of Rs.9,000 received as interest from Bazpur Cooperative Sugar Factory Ltd. is not covered under Section 14(3) of the Income Tax Act? (2) Whether on the facts and in the circumstances of the case, and on a true and correct interpretation of the various clauses of the agreement, the sum of Rs.51,295 and Rs.58,937 received as interest on advances would not be assessee 's income from coal and sugar business and would thus be exempt under Section 14(3) of the Income Tax Act, 1922? At the hearing it has been clarified by counsel for both parties that in the second question referred to above, the dispute is confined to the sum of Rs.51,295 only.