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The High Court of Madhya Pradesh rejected the application filed by the Commissioner of Income-tax, seeking reference of questions of law related to the treatment of sales tax subsidy as revenue or capital receipt for the assessment year 1987-88. The Tribunal upheld the order of the Commissioner of Income-tax (Appeals) based on a previous decision, leading to the dismissal of the appeal. The application for reference was rejected as the matter was considered concluded by the court's decision. The application was accordingly rejected, with a counsel fee of Rs. 750 fixed for the applicant.
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