2007 (4) TMI 61

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..... sessee entitle for exemption
JUDGEMENT MADAN B. LOKUR, J. - The Revenue is aggrieved by an order dated 6th January, 2006 passed bythe Income Tax Appellate Tribunal, Delhi Bench A in ITA No.2590/Del/2002 relevant for the assessment year 1987-88 and ITA No.2591/Del/2002 relevant for the assessment year 1998-99. 2. The sole question that has arisen in this appeal is whether the Assessee who is e .....

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..... rissa State Warehousing Corporation vs. Commissioner of Income Tax [1999] 237 ITR 589 wherein the Supreme Court has interpreted Section 10(29) of the Act which uses the expression 'derived from' which expression is missing in Section 10(22) of the Act. The Supreme Court held that the expression 'derived from' is intended to give a restrictive meaning to the word 'income' as used in Section 10(29) .....

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..... o be construed strictly as regards the applicability thereof to the case of the assessee once it is found that the same is applicable, the same are required to be interpreted liberally. (See Tata Iron and Steel Co. Ltd. v. State of Jharkhand [2005] 4 RC 641; [2005] 140 STC 284 (SC); [2005] 4 SCC 272; Government of India v. Indian Tobacco Association [2005] 5 RC 379; [2005] 7 SCC 396 and Commission .....

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