TMI Blog1999 (7) TMI 40X X X X Extracts X X X X X X X X Extracts X X X X ..... f the assessment year 1970-71, the Income-tax Appellate Tribunal has referred the following questions for the opinion of this court, at the instance of the Revenue : "1. Whether, on the facts and in the circumstances of the case, the expenditure of Rs. 9,068 incurred by the assessee on the foreign tour of Dr. Bharat Ram to attend the meetings of the International Chamber of Commerce was deductib ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee itself, relating to the assessment year 1969-70, reported as Delhi Cloth and General Mills Co. Ltd. v. CIT [1986] 158 ITR 64. The question is accordingly answered in the affirmative, i.e., in favour of the assessee and against the Revenue. Similarly, in view of the decision of this court in the case of the assessee itself in respect of the assessment year 1965-66, reported as Delhi Clo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al did not agree with the view taken by the Income-tax Officer and thus allowed the relief as claimed by the assessee for the whole year. On these facts, the aforenoted question has been referred for the opinion of this court. The short question for consideration is as to what meaning is to be ascribed to the phrase "6 per cent. per annum." as appearing in section 80J of the Act. In other words ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , opined that the deduction under the said section has to be allowed in full without reducing the same in proportion to the part of the year during which the undertaking was not in productive operation. Besides, it has also been brought to our notice by learned counsel for the assessee that the Central Board of Direct Taxes has accepted the interpretation placed on the phrase "per annum" by the Ma ..... X X X X Extracts X X X X X X X X Extracts X X X X
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