TMI Blog1998 (8) TMI 67X X X X Extracts X X X X X X X X Extracts X X X X ..... nder section 256(1) of the Income-tax Act, 1961, referable to assessment years 1976-77 and 1977-78 made at the instance of the Revenue 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 Tribunal was correct in law in confirming the order of the Commissioner of Income-tax (Appeals) deleting and disallowing of R ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e stated. The assessee is a subsidiary of General Insurance Corporation of India and is engaged in the business of general insurance. An amount of Rs. 8,99,429 was claimed as a deduction on account of entertainment expenses and entertainment allowances. The assessee was held entitled to a deduction of Rs. 30,000. The balance amount of Rs. 8,69,429 was disallowed. The matter went up in appeal to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in appeal to the Income-tax Appellate Tribunal. So far as the view taken by the Commissioner of Income-tax (Appeals) by reference to sections 37(2A) and 35B of the Act is concerned, it was upheld by the Income-tax Appellate Tribunal. Consequently, the direction of the Commissioner of Income-tax (Appeals) requiring the Inspecting Assistant Commissioner to modify the assessment in accordance with th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... evenue and against the assessee. Before parting, we may place on record that though the reference is for two years and hence registered at two numbers the subject-matter of the question is referable to the assessment year 1977-78 only. We do not find any question referred or framed for the assessment year 1976-77. We leave it at that and direct that one copy each of this order shall be placed on ..... X X X X Extracts X X X X X X X X Extracts X X X X
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