2001 (6) TMI 21

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..... essment years 1986-87 and 1987-88, respectively: "Whether, on the facts and in the circumstances of the case, the Income tax Appellate Tribunal was right in law in holding that the expenditure of Rs.52,945 for the assessment year 1986-87 incurred as security charges in respect of the land and factory building should be treated as loss from a separate sub-source of income and eligible for set off .....

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..... eligible for set off against other incomes. The said contention of the assessee was accepted by the Tribunal and as against this, this reference has been made. The learned advocate for the Revenue fairly placed before us the decision in the case of CIT v. Gannon Dunkerley and Co. (P.) Ltd. [2000] 243 ITR 646 (Mad), wherein it was held that the expenditure that had been incurred by the official .....

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