1998 (1) TMI 54

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..... year 1974-75 and made at the instance of the assessee seeking the opinion of the High Court on the following question of law : "Whether, on the facts and in the circumstances of the case, the premium of Rs. 4,75,322 earned on transfer of import entitlements is income liable to tax?" The plea raised on behalf of the assessee was that the transfer of import entitlements amounted to a transfer o .....

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..... ion 2 of the interpretation clause of the Act whereby any sum chargeable under clause (iiia) of section 28 is included in the definition of "income". These amendments, though inserted by the Finance Act of 1990, have been given a retrospective effect from April 1, 1962. The assessment year 1974-75 is clearly covered by the amendment. Thus whatever might have been the controversy earlier, the same .....

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