1986 (8) TMI 36

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..... ct, 1961 (hereinafter referred to as " the Act "), the Income-tax Appellate Tribunal, Indore Bench, has referred the following question of law to this court for its opinion : " Whether, on the facts and in the circumstances of the case, the Tribunal is justified in holding that the assessees, who is an association of persons, is entitled to deduction as per clause (c) of sub-section (1) of secti .....

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..... der section 80L of the Act by holding that exemption under section 80L of the Act was admissible to an association of persons. The Revenue thereupon preferred an appeal before the Tribunal which was dismissed. Hence, at the instance of the Revenue, the aforesaid question of law has been referred to this court for its opinion. At the time of hearing, Shri Mukati, learned counsel for the Revenue, .....

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..... wever, contended that the assessee could not have been assessed in the status of an association of persons. But the question as to whether the assessee can be assessed in the status of an association of persons has not been referred to us and it does not arise out of the order passed by the Tribunal. From the order passed by the Tribunal, it is clear that the assessees had never disputed that the .....

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