At the instance of the assessee, the Tribunal stated a case and referred the following three questions of law for the opinion of the High Court: (1) "Whether on the facts and in the circumstances of the case, the assessments for the years 1954 55, 1960 61 and 1961 62 were validly reopened under Section 147(a) of the Income Tax Act, 1961?" (2) "Whether on the facts and in the circumstances of the case, the provisions of Section 24(1)(i)(b) of the Income tax Act, 1961, were applicable?" (3) "Whether on the facts and in the circumstances of the case, the expenditure which was not allowed while completing the original assessments could be considered for allowance in course of assessments re opened under Section 147(a)?" As stated earlier, the High Court answered the questions against the assessee, but granted a certificate under Section 261 of the Act as in its opinion two important questions arose out of the judgment.