1970 (12) TMI 15

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..... l Income-tax Act, 1944, the question is as follows : "Whether, on the facts and in the circumstances of the case, and on a correct interpretation of rule 4(2)(a), the Appellate Tribunal was justified in holding that the market value for unsold paddy, if sold in the next year to the procurement department, must be calculated under rule 4(2)(a) on the procurement rate of the accounting year and no .....

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..... in particular by clauses (c), (d), (f), (h), (i) and (j) of sub-section (2) of that section, read with the notification of the Government of India in Department of Food No. PY 603/2/1, dated the 21st October, 1946. The order was passed with the concurrence of the Central Government. By sub-paragraph (4) of paragraph 3 of this order all producers of food grains were prohibited from selling or othe .....

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..... nt had also fixed the maximum prices per maund at which rice in husk (paddy) of different varieties may be bought or sold in wholesale quantities in several districts. In the premises aforesaid, it is purely academic to argue about procurement rate and market rate operating simultaneously in the accounting year with which we are concerned in this reference. Our answer to the question in this ref .....

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