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Issues: Interpretation of section 16 of the Income-tax Act, 1961 regarding standard deduction for an assessee receiving salary income from two employers without a car for personal use.
Analysis: The judgment by the High Court of Madras involved a dispute regarding the standard deduction claim by an assessee who was receiving salary income from two different employers. The primary issue was whether the assessee was entitled to claim separate standard deductions for the salary income received from each employer. The assessee, Mr. U. Mohan Rao, was a managing director in two companies and received remuneration from both. One company provided him with a car for employment purposes, while the other did not provide any conveyance. The Income-tax Officer initially allowed only a consolidated deduction of Rs. 1,000, considering both salaries as chargeable under the head "Salaries." However, the Commissioner of Income-tax (Appeals) accepted the assessee's claim for separate deductions, leading to an appeal by the Department. The High Court analyzed the relevant provisions of the Income-tax Act, particularly section 16 and the Explanation introduced by the Taxation Laws (Amendment) Act, 1984. The Explanation clarified that where an assessee receives salary from multiple employers, the deduction should be computed based on the aggregate salary without exceeding the specified amount. The proviso also addressed situations where a car is provided for personal use, limiting the deduction to Rs. 1,000. In this case, the court consolidated the salaries from both employers and determined that the assessee was entitled to a standard deduction of Rs. 3,500, not Rs. 4,500 as claimed. The court emphasized that granting two standard deductions for salaries from two employers was incorrect. The court revised the question referred by the Tribunal to align with the correct issue, focusing on whether the assessee was entitled to a standard deduction of Rs. 3,500 due to receiving salary income from two employers without a car provided for personal use. Ultimately, the High Court ruled in favor of the assessee, affirming the Tribunal's decision to allow a standard deduction of Rs. 3,500 and rejecting the Department's appeal. The judgment clarified the application of section 16 in cases of multiple salary incomes and the impact of the Explanation and proviso on standard deductions, providing a comprehensive analysis of the legal principles involved in determining the allowable deduction for the assessee.
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