1978 (11) TMI 50

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... relates to the assessment years 1966-67 and 1967-68. The Tribunal has referred three questions of law for our opinion. The first question relates to the taxability of receipts of money for surrender of import entitlements. In Agra Chain Manufacturing Co. v. CIT [1978] 114 ITR 840 (All), it was held that such receipts are revenue in nature. Hence, this question is to be answered against the assess .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... ion. It was also found that the assessee had created the requisite development rebate reserve. It concluded that, in view of the clear provisions of s. 33(1)(b), development rebate was allowable despite the fact that the entire cost had been allowed by way of deduction. It has not been doubted before us that the items in question were the capital assets of the assessee. The assessee had created t .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X