9911796707
TMI Blog2006 (8) TMI 332X X X X Extracts X X X X X X X X Extracts X X X X ..... the same was eligible for the relief u/s 36(1)(viii) of I.T. Act as the interest income from such investments and deposits were made firstly because all such funds required for the business activity were lying idle and hence invested in short term deposits and further because these invests were made out of business compulsion or business necessity like providing bank guarantees for certain transactions, for opening LC for export purpose, for getting the facility and services of Government departments and lastly these deposits had to be made otherwise the business activity could not be carried on by the assessee. Hence in view of our detailed discussion and conclusions drawn thereon the order of Assessing Officer in disallowing the benefit u/s 36(1)(viii) in respect of interest income on deposits, from investments, ICDs and guarantee fee is upheld and the order of the CIT(A) in allowing the benefit u/s 36(1)(viii) in respect of interest earned on the amounts deposited by the assessee for a period of three months disbursement for the succeeding period and the guarantee fee earned by the assessee is set aside and the other part of the order of the CIT(A) in allowing the benefit u/s 36 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nce 1990-91 to 1995-96 based on the provision created in the books of account. Thus, we find no merits in the order of CIT(A) in confirming the impugned addition made by the Assessing Officer and so the order of CIT(A) in this regard is set aside and Ground No. 4 of the assessee s appeal is allowed. In the light of our findings recorded hereinabove the Ground Nos. 1, 2 and 3 of the assessee s appeal and Ground No. 7 of the Revenue s appeal stand partly allowed in the manner as indicated in this order and Ground No. 4 of the appeal of the assessee are allowed. In the result, the instant appeals of the assessee as well as that of revenue are partly allowed. - HON'BLE D.R. SINGH, JUDICIAL MEMBER AND G.S. PANNU, MEMBER (A) For the Appellant : M.S. Syali, V.S. Rastogi And Tarandeep Singh For the Respondent : P.V. Rao ORDER D.R. Singh, Judicial Member 1. These two appeals, one filed by the assessee and the other filed by the Revenue against the Order of the CIT(A) passed in Appeal No. 44/99-2000 dated 14-12-1999 were heard together and are being disposed of by this common order for the sake of convenience. 2. The assessee in its appeal has taken following effective grounds : (1) Th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ide with respect to the above-mentioned grounds. 4. At the out set of the appellate proceedings, the authorized representatives of both the parties submitted that in the instant appeals, the COD approval has not been granted in respect of Ground No. 5 of the appeal of the assessee and Ground No. 2 of the appeal of the Revenue and accordingly these respective grounds taken by the parties in their respective appeals are hereby rejected. 5. The issue involved in Ground Nos. 1 to 3 of the appeal of the assessee and Ground No. 1 of the appeal of the Revenue is identical so the same are taken up together and are being disposed of as hereunder. 6. The relevant and material facts for the disposal of the issue relating to deduction under section 36(1)( viii ) of the Act are that the return of income was filed by the assessee on 28-11-1996 declaring a total income of Rs. 1,99,04,27,375. This return was processed under section 143(1)( a ) at Rs. 2,01,65,81,357 on 28-8-1997. Another Revised Return was filed on 28-8-1997 disclosing a total income of Rs. 1,86,62,44,220. The Revised Return was processed under section 143(1)( a ) on 16-9-1997 at a total income of Rs. 1,89,23,98,215. The assessee i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hich comes to 37.38 per cent had been taken as the ratio to arrive at the proportionate expenditure for earning a particular type of income. For example, the total interest on ICDs is Rs. 24.19 crores. The proportionate expenditure to be deducted, according to the assessee, from the interest on ICDs is taken as 37.38 per cent of Rs. 24.19 crores, which comes to Rs. 9.04 crores. According to the Assessing Officer, this is not a correct method to arrive at the income, which qualifies for the deduction under 36(1)( viii ). The deduction has been allowed by the Assessing Officer on the income on long-term finances after reducing the entire gross amount of other income such as interest on investments, interest on deposits, lease income etc. There is no expenditure involved in earning interest on investments or interest on deposits. These incomes have been earned on the surplus fund, which the assessee had earned over a period of time. There is no expenditure in the form of interest on borrowed capital. The entire establishment is for making long-term financing to the power projects. This is the reason why the CBDT had notified the assessee-company qualified for deduction under section 3 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n of Rs. 2,61,54,000, which was not to be allowed and the deduction under section 36(1)( viii ) was only to be allowed on the income earned on long-term financing for industrial development or other activities as given in the provision and, therefore, these amounts would not qualify for deduction. 11. Aggrieved with the order of Assessing Officer, the assessee filed an appeal before the CIT(A) and contended before him that the assessee-company is engaged in the business of providing long-term finance of over five years duration for power projects resulting in interest receipt on these long-term loans but during the carrying on of such business, some incomes have resulted from money kept in bank deposits and from lease income etc. These receipts are part of the business of long-term finance and integrally connected with the same. 12. Now coming to the individual items, the learned AR for the assessee contended before the CIT(A) that there was a condition in project agreements with Asian Development Bank, International Bank for Reconstruction and Development that the assessee Corporation shall maintain liquidity equal to projected three months disbursements. The assessee further prod ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... expense claimed by the assessee. The correct method was to examine each expense and see its applicability to the earning of income under each head because each and every income earned does not qualify for deduction under section 36(1)( viii ) of the Act but one has to examine each item separately. 15. Thereafter the CIT(A) while considering interest earned on bank deposits observed that The A.R. has clearly stated that it is surplus funds. All funds required for business activity, which are lying idle are invested in short-term deposits. Earning of interest on deposits by itself is covered under the head Income from other Sources. It is only when it is a business compulsion or business necessity that the funds have to be invested then it becomes integral to the conduct of the business and income from business. Such like situation can be a business necessity of providing bank guarantee for certain transactions for which the assessee has to make fixed deposit. Another example can be for opening an LC for export purpose. The assessee is required to make a fixed deposit and incidentally earns income. One more example could be making of fixed deposit for getting the facility and servic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... his section. But sometimes the borrower cannot fulfil the conditions for taking loans. In such situations in order to help the borrower in this development of infrastructure, they tried to help the concern by leasing these assets. In this case the borrower happens to be Andhra Pradesh of U.P. State Electricity Board. When such a Government concern as the assessee helps another Government concern as a State Electricity Board in generating power on long-term basis by leasing its assets, I see no reason why it should not be treated as providing long-term finance for industrial or agricultural development or development of infrastructure facility in India This will be treated as income qualifying for the deduction. 17. In respect of guarantee fees, the CIT(A) observed as under : The guarantee amount, as explained by the A.R., is paid to guarantee supplier about the payment to be made by the concern to which the assessee is providing long-term finance. The guarantee in this case has been provided for U.P. State Electricity Board. This is obviously an integral part of business activity and is income from business. The Assessing Officer is directed accordingly. 18. The Ground Nos. 1, 2 an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... viii ) of the Income-tax Act. In support thereof he placed reliance on CIT v. Neopolypack (P) Ltd. [2000] 245 ITR 492 (Delhi), Director of Income-tax v. Apparel Export Promotion Council (No. 1) [2000] 244 ITR 734 (Delhi) and CIT v. A.R.J. Security Printers [2003] 264 ITR 273 relevant Page 279. 22. In the instant case, the assessment year under consideration before us is 1996-97 wherein, undisputedly, there was a change in provisions of section 36(1)( viii ) by the Finance Act, 1995 w.e.f. 1-4-1996 and by the Finance (II) Act, 1996 w.r.e.f. 1-4-1996 relevant to assessment year 1996-97 under consideration before us, as has already been mentioned by us herein above in this order. 23. From the ratio of the decisions ( supra ) it is clear that the doctrine of res judicata does not strictly apply to Income-tax proceedings and where an issue has been considered and decided consistently in a number of assessment years in a particular manner, for the sake of consistency, the same view should continue to prevail in subsequent years provided there is no material change in facts and law, but, in the instant case in the year under consideration, undisputedly, there is a change in law, so, in ou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... age and neither should anything be added nor should something be subtracted therefrom unless there are adequate grounds to justify the inference that the Legislature clearly so intended. It is also well-settled that in a taxing statute one has to look merely at what is clearly stated. The meaning and extent of the statute must be collected from the plain and unambiguous expression used therein, rather than from any notions, which may be entertained by the court as to what is just or expedient. 26. In Cambay Electric Supply Industrial Co. Ltd. v. CIT [1978] 113 ITR 84 the Apex Court held that the expression derived from is narrower than the expression attributable to . Similarly, the Apex Court in its decision rendered in the case of National Organic Chemical Industries Ltd. v. CCE 106 STC 467 (SC); held that the word derived is usually followed. by the word from and it means get or trace from a source; arise from, originate in; show the origin or formation of. 27. In the case of CIT v. Jameel Leathers Uppers [2000] 246 ITR 97 (Mad.) their Lordships held that cash assistance, duty drawback, and import entitlements though undoubtedly attributable to business carried on by the assesse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... while examining the question of import entitlements eligible for deduction under section 80HH at page 584, their Lordships held as under : We do not think that the source of the import entitlements can be said to be the industrial undertaking of the assessee. The source of the import entitlements can, in the circumstances, only be said to be the Export Promotion Scheme of the Central Government whereunder the export entitlements become available. There must be, for the application of the words derived from , a direct nexus between the profits and gains and the industrial undertaking. In the instant case, the nexus is not direct but only incidental. The industrial undertaking exports processed sea food. By reason of such export, the Export Promotion Scheme applies. Thereunder, the assessee is entitled to import entitlements, which it can sell. The sale consideration therefrom cannot, in our view, be held to constitute a profit and gain derived from the assessee s industrial undertaking. 30. In Ritesh Industries Ltd. s case ( supra ) their Lordships while considering the expression derived from held as under : There must be, for the application of the words derived from , a direct ne ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ntended to give the benefit of deduction to all business income. If the intention of the Legislature was to grant relief to all business income, it could have used the expression, profits and gains of industrial undertaking . The fact that the Legislature has used the expression profits and gains derived from the industrial undertaking has some significance and it connotes that the immediate and effective source of income eligible for grant of relief under section 80HH of the Act must be the industrial undertaking itself and not any other source. The mandate of law is that unless the source of the profit is the undertaking, the assessee is not eligible to claim deduction under section 80HH of the Act. Mere commercial connection between the income and the industrial undertaking would not be sufficient. We find no compelling reasons to give a wider meaning to the expression, derived from in section 80HH of the Act, as the nature of the provision, intended to give tax deduction, does not warrant a wider meaning being given to the expression, derived from in section 80HH of the Act. 32. In Pandian Chemicals Ltd s case ( supra ) their Lordships approving/affir-ming the decision of Madra ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing of the commodities, as such the question of the interest income accruing therefrom being exempt from tax as has been held by the Tribunal does not and cannot arise . 35. In the case of Hindustan Lever Ltd. v. CIT [1999] 239 ITR 297 (SC), the Apex Court again had an occasion to deal with meaning of the word derived and their Lordships have held that the word derived is not a term of art. Its use in the definition indeed demands an enquiry into the genealogy of the product. But the enquiry should stop as soon as the effective source is discovered. In the genealogical tree of the interest land indeed appears in the second degree, but the immediate and effective source is rent, which has suffered the accident of non-payment. 36. In the instant case, the immediate source of the profit is sale of goods. The export of other goods is not even the second degree but it has to be traced to an even more remote degree. The import was of palm oil. The import was possible because of earlier export of goods at a loss. In the chain of sequence the earlier export would be four degrees away. Thereafter their Lordships concluded that assessee s profit from sale of goods in India could not be said ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... me-tax Act while considering the meaning of the word derived used in section 80 HH at pages 805 and 806 observed as under : No doubt it is true, section 80HH is meant to give a tax rebate to certain categories of assessees and one, who wants to claim such a relief, must strictly satisfy the requirements prescribed therein. He must establish that his profits and gains were derived from his industrial undertaking or the business of hotel. Axiomatic a proposition of law it is that it is not sufficient, if a commercial connection is established between the profits earned and the industrial undertaking and the law requires that such profits must have been derived from the industrial undertaking. The industrial undertaking, itself must be the source of that profit. The business of the industrial undertaking must strictly yield that profit. It must be the direct source of profit and not a means to earn any other profit. 41. Again, in CIT v. Khemka Container (P.) Ltd. [2005] 144 Taxman 109 (Punj. Har.) in Paras 10 and 11 held as under : The amount of insurance claim received by the assessee cannot be said to be income derived from industrial undertaking so as to qualify for deduction under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... considered as income derived from the industrial undertaking. The immediate source of the income was the transport subsidy scheme and not the industrial undertaking. 45. In CIT v. Eastern Seafoods Exports (P.) Ltd. [1995] 215 ITR 64 (Mad.) their Lordships while considering the entitlement of the assessee to special deduction under section 80J in respect of profit from sale of import entitlements held that the word derived in section 80J of the Income-tax Act, 1961, is not a term of art. Its use in the definition indeed demands an enquiry into the genealogy of the product. But the enquiry should stop as soon as the effective source is discovered. Profit or gain can be said to have been derived from an activity carried on by a person only if the said activity is the immediate and effective source of the said profit or gain. There must be a direct nexus between the activity and the earning of the profit or gain. The income, profit or gain cannot be said to have been derived from an activity merely by reason of the fact that the said activity may have helped to earn the said income or profit in an indirect or remote manner. The expression derived from the business in section 80J shoul ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ns that it is not necessary that the interest receipt for qualifying for deduction under section 80HHC must be derived from the export of goods or merchandise in case the interest receipt simply forms part of profits and gains of business. From the above discussion it is evident that the case law ( supra ) relating to section 80HHC, holding interest receipt as business income eligible for deduction under section 80HHC, was, infact, not concerned with the meaning of the word derived from or from the issue whether the interest receipt was derived from the business of export of goods or merchandise, whereas in sections 80HH, 80-I, 80J and 36(1)( viii ) we are mainly concerned with the words derived from because the receipts of the assessee for making the assessee eligible for relief under these sections must be derived from the business specified in these sections. Hence, the case law relied upon by the learned AR for the assessee is of no assistance to the assessee in throwing any light on the implication of the meaning of the word derived from used in the section 36(1)( viii ) of I.T. Act because for allowing the deduction under section 80HHC it is only sufficient if the income is h ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the decision of the Apex Court in the case of Pandian Chemicals Ltd. ( supra ) and the decision of the jurisdictional High Court of Delhi in the case of Ritesh Industries Ltd. ( supra ), which is squarely applicable to facts and the issue considered by the 3rd Member decision in the case of Gallium Equipment (P.) Ltd. ( supra ), as the same were not available before the Tribunal at the time of deciding the case ( supra ). 49. In an another case Honda Siel Power Products Ltd. v. Dy. CIT [2001] 77 ITD 123 (Delhi), referred to by learned AR for the assessee the Tribunal while allowing the deduction under section 80HHC in respect of interest earned first observed that the link of investments was inextricably in nature of business because the assessee was paying interest on its borrowings, which were for the purpose of business, and the business of the assessee was a seasonable one and, accordingly, for few months funds were surplus and those funds were invested for a short period, so that the idle money could be utilized and the burden of the payment could be lessened. Therefore, the assessee reduced the interest payment from interest income and net of both the items was taken into P ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r the payment of which it was otherwise entitled under the contracts and which payment had been delayed as a result of disputes between the parties. The interest awarded could not be separated from the other amounts granted to the respondent under the awards and treated as Income from other sources . It is well-settled that interest can be assessed under the head Income from other sources only if it cannot be brought within one or the other of the specific heads of charge. Hence the decision ( supra ) relied upon by the learned AR for the assessee is of no help to the assessee in resolving the implication of the meaning of the words derived from used in section 36(1)( viii ) of Income-tax Act under consideration before us. 51. Lastly, learned AR for the assessee laid strong emphasis on the unreported case of Sita World Travel (I) Ltd. v. Dy. CIT IT Appeal Nos. 6717 and 6715/Delhi/96 assessment years 1989-90 and 1993-94 decided by ITAT-Delhi Bench on 6-3-2004 and contended that the Tribunal even after discussing the case of Pandian Chemicals reported in 262 ITR 278 and various other decisions held that the assessee was entitled to deduction under section 80HHD of the Act on the inte ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... referring to the implication of the words derived from as given in the case of Pandian Chemicals Ltd. and similar other decisions of the High Courts but was mainly decided on the reasoning that on identical facts in the previous years the tribunal in the case of that very assessee had allowed such deduction and further because the ratio of Pandian Chemicals Ltd. ( supra ) did not apply to the case of the assessee for deduction under section 80HHD because the provisions of section 80HH referred in the case of Pandian Chemicals Ltd. ( supra ) were not akin to the provisions of section 80HHD under consideration before the Tribunal in the case of Sita World Travel (I) Ltd. ( supra ) but, the section 80HHD was akin to section 80HHC, which was under consideration before the special bench of the Tribunal in the case of Rajeev Enterprises ( supra ). Before moving ahead we may mention that in the case of Sita World Travel (I) Ltd. ( supra ), the Tribunal has mentioned that the provisions of section 80HHC were akin to the provisions of section 80HHD but while discussing the case of Rajeev Enterprises ( supra ) referred in the case of Sita World Travel (I) Ltd. ( supra ) we have already discu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nancing means only advancing of cash as loans because this is only the form of providing long-term finance but in our opinion where the assessee, as in the instant case, is helping in generating infrastructure facilities for the country providing long-term finance should also mean to include making available assets on lease for a period of more than 5 years to the parties because of the exorbitant cost of such assets. We agree with the logic given by Ld. AR for the assessee that though providing money as loan and advances to the parties is an activity which is clearly covered by this section, but, at the same time where the borrower sometimes can not fulfil the conditions for taking the loan then in that situation if the assessee in order to help the borrower in development of infrastructure helped by leasing the assets on long term basis by charging interest thereon then the same should also be treated as the business of providing long term finance of industrial or agricultural development or development of infrastructure facility in India and hence this lease income under consideration is held to be the income of the assessee from the business of providing long term finance for i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n in another language, which means that there is no reason to depart from that ordinary meaning of the words derived from . Similarly, the Hon ble Apex Court in the case of Sterling Foods ( supra ) have held that the word derive is usually followed by the word from and it means: get, to trace from a source; arise from; originate in; shown the origin or formation of. Further, the Apex Court in the case of Hindustan Lever Ltd. ( supra ) has held that the word derived is not a term of art. Its use in the definition indeed demands an enquiry into the genealogy of the product. But the enquiry should stop as soon as the effective source is discovered. In Cement Distributors Ltd. ( supra ) their Lordships of Delhi High Court held that the words derived has to be assigned a restricted meaning as compared to the words attributable to or referable to . From the decision of the Apex Court in the case of Pandian Chemicals Ltd. ( supra ) and the decision of jurisdictional High Court of Delhi in the case of Ritesh Industries Ltd. ( supra ) and the decision in the case of Cement Distributors Ltd. ( supra ) it is clear that the words derived from used in sections 80HH and 80-I must be understood a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ase the assessee wants to avail benefit/relief under that section in which that business or businesses of industrial undertaking is specified as occurring in sections 80HH, 80-I, 80J and 36(1)( viii ) etc. For deriving the benefit under the section the assessee is required to show the immediate source of the profit and gain, and it would not be sufficient for the assessee to establish the commercial connection between the profits and gains earned and the industrial undertaking or such businesses specified in that section to obtain such benefit/relief. 63. In the instant case, it is not in dispute that the assessee is engaged in the business of long term finance for inter alia development of infrastructure facility in India. Section 36(1)( viii ) provides for deduction to the assessee in respect of any special reserve, created by an assessee, of an amount not exceeding 40 per cent of profits derived from such businesses i.e. business of providing long term finance, computed under the head profits and gains of business . Once the income can be said to be derived from such business the assessee becomes eligible to the benefit under section 36(1)( viii ) of IT Act. This means that any ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ot be just or expedient on our part to include the above income eligible for deduction under section 36(1)( viii ) merely because according to the assessee these investments and income earned from interest, guarantee fee and lease transaction was under compulsion and not by choice whereas in the instant case the immediate source of the above-mentioned income of the assessee is not the immediate business of providing long term finance but can only be said to have a commercial connection with the business of the assessee and therefore interest income and guarantee fee under consideration cannot be said to have been derived from the business of providing long term finance and hence not eligible for benefit/relief under section 36(1)( viii ) of IT Act. Hence in view of our detailed discussion and conclusions drawn thereon the order of Assessing Officer in disallowing the benefit under section 36(1)( viii ) in respect of interest income on deposits, from investments, ICDs and guarantee fee is upheld and the order of the Commissioner of Income-tax (A) in allowing the benefit under section 36(1)( viii ) in respect of interest earned on the amounts deposited by the assessee for a period of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed as income from other sources on which expenditure cannot be allowed. Hence, we conclude that in the existing facts and circumstances the interest earned by the assessee on short term deposits and investments for a period of three months out of compulsion and business necessity as well as interest earned on ICDs and guarantees as guarantee fee was an integral part of the business activity of the assessee and therefore the same cannot be treated as income from other sources and is to be considered under the head business income. 67. We further agree with the order of the Commissioner of Income-tax(A) that the assessee has neither any justification nor there can be any system of allocating pro rata expenses at the rate of 37.38 per cent keeping in view the nature of the income which has been held by us, hereinabove in this order, as business income under the head the expenses claimed by the assessee at the rate of 37.38 per cent has been rightly rejected by the Commissioner of Income-tax (A) in view of the detailed observations and conclusions in his order. We further uphold the order of the Commissioner of Income-tax (A) wherein he observed that the Assessing Officer should have e ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n of the profit as an item of expenditure. Still, the assessee cannot allow deduction just because it has not been allowed for bad and doubtful debt by the C AG. Further, according to the Assessing Officer, the assessee has been following mercantile system for the expenditure but for income it has been following the cash system as per the auditors mentioned in the Tax Audit Report of the assessee. Further, according to the Assessing Officer, the major income of the assessee is on account of interest etc. on loan and advances given and if the income is accounted for, only when it is actually received by the assessee, there is no reason why on the provision of bad and doubtful debt could be made. He further observed that in fact the assessee would have earned Rs. 404.76 crore more than what has shown as income in the P L Account, if it had followed mercantile system on incomes too. In other words, the accrued income which is not accounted for to the extent of Rs. 404.76 crore as per Note No. 3, Schedule No. 16 Page No. 44 of the Annual Accounts but the same has not been accounted for as income because the assessee has not taxing the receipt of cash basis. He further observed that thu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f. The CAG, however, in the year under consideration, in its comments on the accounts for the year ending 31-3-1994 (as per PB pg. 20) characterized such provision as reserve and in pursuance of those comments, since being binding on the assessee in subsequent years, had shown the amount below the line in the appropriation account as indicated at internal page 27 of PB pg 22 whereas the amount appears in Schedule II under the head Reserve and Surplus but nevertheless, the amount was described as Provision for bad and doubtful debts under section 36(1)( viia )( c ) of IT Act, 1961. 76. We further find that in response to the sole objection raised by learned DR, that the assessee in this manner would avail of a double deduction, the assessee filed a certificate before the Tribunal to show that the assessee had not claimed any double deduction in respect of bad debts in any of the assessment years 1996-97 to 2005-06 which indicates that there was a fine link between such provision of the past and this fresh provision of the amount which has to be one year in which all the entries are to be made. Hence, we are of the opinion that the presentation of the concerned amount under schedule ..... X X X X Extracts X X X X X X X X Extracts X X X X
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