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Issues:
1. Interpretation of deduction under section 80TT of the Income-tax Act, 1961. 2. Applicability of the Supreme Court's decision in Distributors (Baroda) P. Ltd. [1985] 155 ITR 120 to the construction of section 80TT of the Income-tax Act. Analysis: The judgment pertains to an application under section 256(2) of the Income-tax Act, 1961, seeking a direction to the Income-tax Appellate Tribunal to refer questions of law arising from an order regarding the deduction under section 80TT. The case involved a lottery prize won by the husband of the applicant-assessee, where the dispute was whether the deduction should be allowed on the net amount or the gross amount of the prize money. The Tribunal's decision was based on the amended provisions of section 80AB and the Supreme Court's decision in Distributors (Baroda) P. Ltd. [1985] 155 ITR 120. The applicant argued that the Tribunal erred in its interpretation and that a referable question of law arose from the decision. Upon review, the court found that the question regarding the deduction did arise from the Tribunal's order, holding it referable. The court held question No. 2 non-referable but allowed the application in part. Consequently, the Tribunal was directed to refer the question for the court's consideration. The court also fixed the counsel's fee and ordered the immediate transmission of the order to the Tribunal for compliance. In conclusion, the judgment addressed the interpretation of deduction under section 80TT of the Income-tax Act and the applicability of the Supreme Court's decision in Distributors (Baroda) P. Ltd. to the case at hand. It clarified the referability of the questions raised by the applicant-assessee and directed the Tribunal to refer the relevant question for further consideration and opinion.
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