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TMI Blog1991 (9) TMI 129X X X X Extracts X X X X X X X X Extracts X X X X ..... e inter alia entitled the authorised agents securing investments in all Small Savings Securities, to receive cash awards @ 1 per cent of their total collections. 2. The assessee, in her capacity as an authorised agent under the Scheme, received a cash prize of Rs. 20,000 from State Government and claimed exemption under section 10(17B) of I.T. Act (the Act) in respect thereof. The I.T. Authorities however rejected her said claim mainly on the ground that the said scheme is not approved by the Central Government as being in " public interest ". 3. The contention of Mr. N.M. Ranka, Advocate is that the provisions of section 10(17B) are required to be given liberal construction in the matter of carrying out an object of public interest and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er in cash or in kind, as a reward by the Central Government or any State Government for such purposes as may be approved by the Central Government in this behalf in the public interest. 5. Three things may be noted in the language of the above provisions. First, payment, whether in cash or in kind, may be made as a reward either by Central Government or State Government. Two, the payment as reward must be approved as being in the public interest. Third, it is the approval of the Central Government and of no other authority which is to be made for the purposes of section 10(17B) of the Act. The question, in the context of administration of the Act, is not whether the act or work done is in the public interest but whether the payment made ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed one of its officer an ITO, for his meritorious services rendered for making the voluntary disclosure scheme a great success and the letter issued by the Central Government granting reward made it quite clear that such reward was granted in the public interest. These facts are clearly distinguishable from those obtaining in the case before us. 8. It was next urged by Mr. Ranka that the assessee was entitled to deduction of 50 per cent out of the entire amount of reward by way of expenses, as per CBDT Circular letter F. No. 168/9/83-IT(A-1) dated 6-1-1984 and letter No, 168/34/85-IT(A-1) dated 24-1-87. We find force in this argument of Mr. Ranka, though the learned Departmental Representative has vehemently opposed the argument on the gr ..... X X X X Extracts X X X X X X X X Extracts X X X X
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