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TMI BlogFinance Act, 1990--Explanatory Notes on the provisions relating to direct taxesX X X X Extracts X X X X X X X X Extracts X X X X ..... s 2, 5, 10, 16, 17, 35K, and Schedule 111 of the Wealth-tax Act, 1957 ; inserted a new section 35EEE in the Wealth-tax Act, 1957 ; amended sections 9, 15 and 16 of the Gift-tax Act, 1958. PROVISIONS IN BRIEF The provisions in the Finance Act, in the sphere of direct taxes relate to the following matters : (i) Prescribing the rates of income-tax on incomes liable to tax for assessment year 1990-91, the rates at which tax will be deductible at source during the financial year 1990-91 from Interest (including interest on securities), dividends, salaries paid to employees, winnings from lotteries or crossword puzzles, winnings from horse-races, insurance commission and other categories of income liable to deduction of tax at source under the Income-tax Act, rates for computation of "advance tax" and charging of income-tax on current incomes in certain cases for the financial year 1990-91. (ii) Retaining with modification as to applicability of the provisions for the levy of surcharge at the rate of 8 per cent. of income-tax. (iii) Amendment of the Income-tax Act, 1961 with a view to - (1) streamlining the tax structure by withdrawing or modifying certain incentives and concession ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... iding for processing of revised returns under the new procedure for assessment ; (23) modifying the definition of "regular assessment" ; (24) conferring power on an Income-tax Officer to reopen assessment with the approval of the Deputy Commissioner ; (25) providing for penalties for certain defaults by mutual funds ; (26) providing for punishment for contravention of prohibitory order served for effecting seizure ; (27) removing anomalies in certain cases ; and (28) modifying the provisions relating to the valuation of jewellery under the Wealth-tax Act. INCOME-TAX Rate Structure I. Rates of income-tax In respect of incomes liable to tax for the assessment year 1990-91. 3. In respect of incomes of all categories of taxpayers (corporate as well as non-corporate) liable to tax for the assessment year 1990-91, the rates of income-tax (including surcharge thereon) have been specified in Part I of the First Schedule to the Finance Act. These are the same as those laid down in Part III of the First Schedule to the Finance Act, 1989. Accordingly, in the case of every person having income exceeding fifty thousand rupees, the amount of income-tax shall be increased by a surc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ere accelerated assessments have to be made, e.g., provisional assessment of shipping profits arising in India to non-residents, assessment of persons leaving India for good during the financial year 1990-91, assessment of persons who are likely to transfer property to avoid tax or where an order has to be passed in a case of search and seizure for calculating the amount of tax on the estimated undisclosed income, etc. 6. The Finance Act, 1989, specified in Part III of the First Schedule that the amount of income-tax deductible or advance tax payable or income-tax payable, as the case may be, shall be increased by a surcharge calculated at the rate of 8 per cent. of the tax so deductible or advance tax or income-tax so payable in the case of a person whose income exceeded fifty thousand rupees. The Finance Act, 1990, provides that the aforesaid surcharge shall be levied in the case of a person whose income exceeds seventy-five thousand rupees. However, no such surcharge shall be levied in a case where the payment is made to or advance tax or income-tax is payable on the income of a non-resident (including non-resident Indian) or a foreign company. III-A. Individuals, Hindu undivi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 15,000 and the rate schedule has been restructured for registered firms carrying on business and also for registered firms carrying on profession. The existing and new rates of income-tax are indicated in the Table below : - TABLE Finance act, 1989 Finance act, 1990 Income level Marginal rate of tax Income level Marginal rate of tax Firms carrying on business Upto Rs. 10,000 Nil Up to Rs. 15,000 Nil Rs. 10,000 - 25,000 5 per cent Rs. 15,000 - 50,000 6 per cent Rs. 25,000 - 50,000 7 per cent Rs. 50,000 - 1,00,000 12 per cent Rs. 50,000 - 1,00,000 15 per cent Above Rs. 1,00,000 18 per cent Above Rs. 1,00,000 24 per cent Firms carrying on profession : Up to Rs. 10,000 Nil Up to Rs. 15,000 Nil Rs. 10,000 - 25,000 4 per cent Rs. 15,000 - 50,000 5 per cent Rs. 25,000 - 50,000 7 per cent Rs. 50,000 - 1,00,000 10 per cent Rs. 50,000 - 1,00,000 13 per cent Above Rs. 1,00,000 15 per cent Above Rs.1,00,000 22 per cent III-D. Local authorities. 10. In the case of local authorities, the rate of income-tax has been specified in Paragraph D of Part III of the First Schedule to the Finance Act, which is the same as in Part III of the First Schedule ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is allowed in computing the taxable profits or gains of business or profession and is equal to the amount deposited/utilised for the purchase of the new ship or aircraft or machinery or plant or 20 per cent. of the profits of business or profession, whichever is less. No deduction will be allowed under this section in relation to any assessment year commencing on or after the 1 st day of April, 1991. [Section 8 of the Finance Act.] (c) Under the provisions of section 33A of the Income-tax Act, an assessee carrying on the- business of growing and manufacturing tea in India is entitled to a deduction in the computation of profits from that business, of a "development allowance" with reference to the actual cost of planting tea bushes. The amount to be so deducted is calculated at the rate of 50 per cent. of such cost. This deduction is available for planting tea bushes on land which had been previously abandoned or which is newly brought under plantation. The deduction under this provision will now be allowed only if the planting of tea bushes has been completed before the 1st day of April, 1990. [Section 9 of the Finance Act.] (d) Under the existing provisions of section 80H ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 32 of the Finance Act.] Clarificatory amendment of the definition of "residence in India"-. 14. Under the existing provisions of sub-clause (c) of clause (1) of section 6 of the Income-tax Act, an individual is said to be a resident in India in any previous year, if in the four preceding years he has been in India for a total period of 365 days or more and has stayed in India for 60 days or more in that previous year. Clause (a) of the Explanation to clause (1) makes an exception in the case of a citizen of India who leaves India in any previous year for the purposes of employment. Such a person is treated as a resident in India only if he stays in India during the previous year for 182 days or more. The aforesaid Explanation does not clarify whether a seaman working on board an Indian ship is also a person leaving India for the purposes of employment. 14.1 In order to remove any doubt in this regard, clause (a) of the Explanation to clause (1) of section 6 has been amended to include therein reference to a member of the crew of an Indian ship. This would ensure that Indian seaman working on board an Indian ship would be treated as resident in India for any year only if the sta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sessment year 1989-90 and subsequent years. [Section 5 of the Finance Act.] New provisions relating to Tea Development Account. 17. Section 33AB inserted by the Finance Act, 1985, provided for deduction in respect of the amount deposited by a tea company with the National Bank for Agriculture and Rural Development. By the Finance Act, 1986, a new section 32AB relating to Investment Deposit Account was inserted in the Income-tax Act. Under this provision an assessee was allowed deduction in respect of amounts deposited with the IDBI/NABARD or the amount utilised during the previous year for the purchase of any new ship, aircraft, machinery or plant. Since the scheme of Investment Deposit Account applied also to taxpayers carrying on the business or profession of growing and manufacturing tea in India, the benefit under the then existing provision in section 33AB relating to Tea Development Account was withdrawn by the Finance Act, 1987. 17.1 The existing provisions of section 32AB have been discontinued by the Finance Act, 1990. However, in view of the continuing need to encourage tea companies to mobilise resources internally for specified purposes, a new section 33AB has been ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n to amounts utilised for the purchase of any machinery or plant to be installed in any office premises or residential accommodation including guest houses ; any office appliance, other than computers ; any other plant or machinery which either is installed in an undertaking producing low priority items specified in the Eleventh Schedule in the Income-tax Act or is an item of plant or machinery entitled to 100 per cent. write off by way of depreciation or for any other reason in any one year. (v) For claiming the deduction, it is necessary that the accounts of the taxpayer are audited by a chartered accountant and the report of the auditor in the prescribed form duly signed and verified is filed along with the return of the relevant assessment year. In cases where the accounts of the taxpayer are required to be audited under any other law, e.g., under the Companies Act, it would be sufficient if the accounts are audited under that law and the audit report as per that law is furnished with the return along with a further report in the form prescribed for the purposes of this provision. The audit report form is being notified separately. (vi) The deduction allowed under this prov ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ts, the creation of reserve was not mandatory. 18.2 The Supreme Court in the case of Shri Shubhlaxmi Mills Ltd. [1989] 177 ITR 193, has held that in order to claim the deduction on account of development rebate, it is obligatory that the reserve should be created in the year of acquisition/installation of machinery or plant, etc., even in a case where there are no profits. If the decision of the Supreme Court is to be followed, then taxpayers who have been following the Board's circulars for many years would be placed in a very difficult situation as their assessments already completed could be reopened. Apart from this, it may run contrary to accounting principles and the assurance given by the Central, Board of Direct Taxes through its circular. 18.3 Though the decision of the Supreme Court has been pronounced only with regard to the provisions relating to development rebate, the underlying principle may apply equally to the grant of investment allowance. Accordingly, sections 32A and 34 have been amended to secure that the condition of creation of reserve even in a year of loss or of insufficiency of profit as laid down by the Supreme Court will not be mandatory in respect of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ble on any loan or borrowing from any public financial institution is allowed only if the same has been actually paid by the assessee before the due date of filing of the return. For this purpose, the term "public financial institution" has been assigned the same meaning as in section 4A of the Companies Act which at present does not cover State Financial Corporations and State Industrial Investment Corporations. 20.1 The scope of section 43B has been enlarged to provide that any sum +payable as interest or any loan or borrowings from any State Financial Corporation or State Industrial Investment Corporation shall also not be allowed as deduction if the same is not actually paid before the due date of filing of return. 20.2 This amendment will take effect from 1st April, 1991 and will, accordingly, apply in relation to the assessment year 1991-92 and subsequent years. [Section 13 of the Finance Act.] Modification of special provisions for computing profits and gains from the business of trading in certain goods. 21. Under the existing provisions of section 44AC of the Income-tax Act, in the case of a trader in alcoholic liquor for human consumption (other than Indian made for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the amount invested or deposited in the life insurance policies, provident funds, superannuation funds, etc., from the income-tax payable by him on his total income. The maximum tax rebate allowable will be Rs. 10,000. In the case of authors, playwrights, artists, musicians, actors or sportsmen (including athletes), the maximum tax rebate allowable will be Rs. 14,000. 22.3 The payments eligible for tax rebate under the new section 88 will be the same as are at present eligible for deduction under section 80C of the Income-tax Act. 22.4 The surcharge, if any payable by an assessee shall be levied on the income-tax payable by him after allowing the tax rebate under the aforesaid provisions. 22.5 The effect of the new provision is illustrated as under : Existing New Rs. Rs. Gross Total Income 70,000 70,000 Deduction under section 80C (assuming savings of Rs. 14,500) 10,000 Nil Total Income 60,000 70,000 Tax on total income 12,900* 15,600** Tax rebate on savings of Rs. 14,500 Nil 2,900 *As per the existing rates. **As per the new rates. Tax payable : Rs. Tax 12,900 Surcharge 1,032 13,932 13,932 12,700 22.6 These amendments will take effect from 1st ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sub-section (1) of section 88A, fails to invest any amount of subscription to the units issued under any scheme referred to in the said sub-section in the eligible issue of capital within a period of six months specified in that sub-section, the Deputy Commissioner may levy a penalty of a sum equal to twenty per cent. of the amount not subscribed by the mutual fund or the Unit Trust of India in the eligible issue of capital. 23.4 This scheme will lapse after 31st March, 1991. 23.5 The newly inserted sections 88A and 271BB will come into force from the 1st day of April, 1991, and will, accordingly, apply in relation to the assessment year 1991-92 and subsequent years. [Sections 30 and 43 of the Finance Act.] Modification of the provisions in respect of deposits under National Savings Scheme. 24. Under the existing provisions of section 80CCA of the Income-tax Act, deduction is allowed to an individual, a Hindu undivided family and certain categories of associations of persons or bodies of individuals, in respect of deposits made under the National Savings Scheme and payments made towards notified annuity plans of the Life Insurance Corporation. The deduction is provided on the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt will be in the units of Mutual Funds specified under clause (23D) of section 10 or Unit Trust of India. The deduction shall be allowed on so much of the amount invested as does not exceed ten thousand rupees. 25.2 The new provision also provides that when any amount in respect of which deduction has been allowed is returned to the assessee either by way of repurchase of the units by the Fund or the Trust or on the termination of the plan, it shall be deemed to be his income for the previous year in which the amount is returned. Further, where the amount is so returned to a member of a Hindu undivided family or of an association of persons after partition of the Hindu undivided family or the dissolution of association of persons, the amount so received shall be deemed to be the income of the recipient. 25.3 A new sub-section (6) and Explanation thereto has been inserted in section 45 to provide that the difference between the repurchase price of the units and the amount invested therein by the assessee shall be deemed to be the capital gains of the year in which the units are repurchased or the scheme is terminated and taxed accordingly. 25.4 Further, a new section 194F has be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... was a revenue receipt and was subject to income-tax. The Special Bench of the Income-tax Appellate Tribunal has, however, in a case, distinguished the aforesaid decision and come to the conclusion that the CCS was a capital receipt and hence not subject to tax. The Department's view all along has been that CCS or any other subsidy received by an exporter as an export incentive is a revenue receipt and hence taxable. 27.1 Similarly, the Department's view as regards drawback of duty and profit on sale of import entitlement licences has been that these are revenue receipts and hence liable to tax. There are many court decisions supporting this view. 27.2 To put an end to litigation which may arise regarding the taxability of these incentives received by exporters, new clauses (iiia), (iiib) and (iiic) have been inserted in section 28 of the Income-tax Act to provide that profit on sale of import entitlement licences, CCS and drawback of duty respectively shall be chargeable to income-tax under the head "Profits and gains of business or profession". These have, further, been included in the definition of the term "income" in clause (24) of section 2. 27.3 These amendments will take ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... year or within such extended period as the Chief Commissioner or Commissioner of Income-tax may allow on being satisfied that the assessee was prevented from complying with this requirement for reasons beyond his control. 28.2 In view of the fact that the exporters/hotels, etc., are being allowed a period of six months from the end of the previous year for bringing foreign exchange into the country, and the taxpayers under the existing provisions are required to file, along with the return, a report from a chartered accountant in the prescribed form certifying, inter alia, that the deduction under this provision has been correctly claimed, section 139 has also been amended to allow such taxpayers who were required to furnish their returns of income by the 31st day of August to file their returns by the 31st day of October of the assessment year. 28.3 Under the existing provisions of section 80HHC, the benefit of deduction is also allowed to supporting manufacturers who export goods or merchandise through recognised export houses or trading houses. A person who processes goods or merchandise and exports the same directly is eligible to claim the deduction under section 80HHC. How ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or Commissioner may allow in this regard. 28.9 These amendments (other than the amendment in section 80HHC(2)(a) relating to exclusion of supporting manufacturer from the requirement of bringing in convertible foreign exchange), will take effect from 1st April, 1991, and will, accordingly, apply in relation to the assessment year 1991-92 and subsequent years. 28.10 The application of section 80HHC read with section 28, as amended by the Finance Act, can be illustrated by the following examples :- Case I Case II Case III Case IV Exclusively export business 2/3 export 1/3 domestic sales 1/2 export 1/2 domestic sales 1/3 export 2/3 domestic sales (i) Turnover (Rs. in lakhs) (a) FOB export 100 100 100 100 (b) Domestic sales Nil 50 100 200 (c) Total turnover [(ia) + (ib)] 100 150 200 300 (ii) Business profits before incentives (assumed figure) 10 15 20 30 (iii) CCS, DBK, I/L 10 10 10 10 (iv) Total profits of the business [(ii) + (iii)] 20 25 30 40 (v) Deduction u/s 80HHC if entire export proceeds, i.e., Rs. 100 lakhs are brought into India within the stipulated period [(iv) × (ia)/(ic)] 20.00 25 X 100/150 = 16.67 30 X 100/200 =15. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ncreased as under : (a) in the case of a co-operative society, twelve assessment years ; (b) in any other case, ten assessment years. 29.5 This amendment will take effect from the 1st April, 1990. [Section 24 of the Finance Act.] Deletion of the definition of the term "security" 30. Under the existing provisions of section 2(42C) of the Income-tax Act, "security" means a Government security as defined in clause (2) of section 2 of the Public Debt Act, 1944. 30.1 The insertion of the definition of the term "security" in section 2 dealing with definition having general application for the purposes of the Act had created anomalies resulting in problems of implementation. Therefore, sub-section (42C) of section 2 of the Income-tax Act has now been omitted. 30.2 Further, section 80L of the Income-tax Act has also been amended to provide that the term "security" appearing therein shall mean a Government security as defined in clause (2) of section 2 of the Public Debt Act, 1944. The same definition of the term "security" has been incorporated in the new section 88 of the Income-tax Act inserted through this Finance Act. This will clarify the nature of the security referred to in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cases of Indian professors, teachers or research workers who work in a foreign university or other educational institutions abroad. Similarly, a deduction under section 80RR equal to twenty-five per cent. of the income received in, or brought into, India in foreign exchange is allowed to a resident individual being an author, playwright, artist, musician, actor or sportsman (including an athlete) who derives income in exercise of his profession from foreign sources. In order to provide a further incentive for bringing foreign exchange into India by these categories of taxpayers, the benefit of deduction in sections 8OR and 80RR has now been enhanced. The new deduction will be:- (i) Fifty per cent. of such income received by the taxpayers ; or (ii) Seventy-five per cent of such income as is brought into India, by or on behalf of the taxpayer in accordance with the Foreign Exchange Regulation Act, 1973, and any rules made thereunder whichever is higher. 32.1 Under the existing provisions of sections 8OR and 80RRA (relating to deduction in respect of remuneration received for services rendered outside India under approved agreements), the deduction is allowed for a maximum contin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... special orders, the provisions of certain sections of the Act, relating to assessment and collection of revenue in respect of any class of incomes or class of cases. The provisions of section 139 relating to filing of return of income, section 234A relating to the charging of mandatory interest for defaults in furnishing return of income and section 234B relating to charge of mandatory interest for defaults in payment of advance tax, may sometimes need relaxation. At present, it is not possible for the Board to relax these provisions. 34.1 Therefore, a reference to sections 139, 234A and 234B has been incorporated in clause (a) of sub-section (2) of section 119 so that the Board is empowered to relax the provisions of these sections applicable to any class of income or class of cases. 34.2 Similar amendments have been made in the corresponding provisions in section 10(2)(a) of the Wealth-tax Act and section 9(2)(a) of the Gift-tax Act. 34.3 These amendments will take effect from 1st April, 1990. [Sections 33, 53 and 59 of the Finance Act.] Allowing the firms to file their returns even if their income is below the taxable limit. 35. Under the existing provisions of sub-section ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t from 1st April, 1990. [Section 35 of the Finance Act.] Conferring power on Assessing Officers to call for return before the end of an assessment year. 37. Under the existing provisions of clause (i) of sub-section (1) of section 142, the Assessing Officer can require any person to furnish a return of his income only after the end of the relevant assessment year. This has given rise to problems because, if the taxpayers do not file their returns of income in time, the Department has no powers to enforce compliance till the relevant assessment year is over. 37.1 To solve this practical difficulty, clause (i) of sub-section (1) of section 142 has been amended so that if a person fails to furnish return of income by the due date mentioned in section 139(1), a notice calling for the return can be sent to him within the relevant assessment year itself. 37.2 Similar amendments have been made in the corresponding provisions of section 16(4) of the Wealth-tax Act and section 15(4) of the Gift-tax Act. 37.3 These amendments will take effect from 1st April, 1990. [Sections 36, 54 and 60 of the Finance Act.] Processing of revised returns under the new Procedure for assessment. 38. U ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... clause (40) of section 2 of the Income-tax Act, defines the expression "regular assessment" to mean the assessment made under section 143 or section 144. Prior to April 1, 1989, an assessment could be made under sub-section (1) as well as sub-section (3) of section 143. However, the new section substituted by the Direct Tax Laws (Amendment) Act, 1987, with effect from April 1, 1989, provides for making of an assessment only under sub-section (3), while under sub-section (1) the return is processed for recovery of any tax or interest due from the assessee or for the issue of any refund due to him without making an assessment. Since the definition of regular assessment in section 2(40) refers to the whole of section 143, without referring to the relevant sub-section, it may raise a controversy whether even the processing of a return under sub-section (1) of the new section 143, is included in "regular assessment". 39.1 Therefore, clause (40) of section 2 has been amended to clarify that regular assessment would mean only an assessment made under sub-section (3) of section 143 or section 144. 39.2 Similar amendment has been made in the corresponding provisions of section 2(cb) of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... section 151 has been amended to provide that an Income-tax Officer can reopen a case, with the approval of the Deputy Commissioner, where an assessment has been completed under section 143(3) or section 147, if he finds that any income has escaped assessment. 41.2 Similar amendments have been made in the corresponding provisions of section 17 of the Wealth-tax Act and section 16 of the Gift-tax Act. 41.3 These amendments will take effect from 1st April, 1990. [Sections 39, 55 and 61 of the Finance Act.] Removal of anomaly in section 268 of the Income-tax Act. 42. Under the existing provisions of section 268, if an assessee is not furnished with a copy of the order, then, in computing the period of limitation for filing an appeal, the time required for obtaining a copy of such order is to be excluded. This provision needs to be applied also in deciding the limitation period for making a reference application under section 256 of the Act. Therefore, an amendment has been made in section 268 to provide that the time required for obtaining copy of the order complained would be excluded in computing the period of limitation for filing reference application under section 256 as well ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... A with rigorous imprisonment up to two years and fine. 44.1 The Finance Act, 1988, inserted a second proviso to sub-section (1) of section 132, which empowers the authorised officer to make a constructive seizure, by a similar prohibitory order, in circumstances where, on account of the physical characteristics, volume or weight of the articles to be seized, it is not possible to take physical possession and remove them to a safe place. The contravention of such a prohibitory order has not been made punishable. 44.2 Accordingly, section 275A has been amended to provide for punishment also for contravention of an order made by the authorised officer under the second proviso to sub-section (1) of section 132. 44.3 Further, section 37A of the Wealth-tax Act contains provision for issue of prohibitory orders similar to those mentioned above. However, there are no provisions in the Wealth-tax Act corresponding to section 275A of the Income-tax Act. To remedy this situation and ensure effective compliance, a new section 35EEE has been inserted in the Wealth-tax Act, which contained provisions similar to those of section 275A of the Income-tax Act discussed earlier. 44.4 These amendm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... authorised representative in case a penalty for concealment has been imposed on him. 46.1 This amendment will take effect from 1st April, 1990. [Section 49 of the Finance Act 1]. WEALTH-TAX Amendment of section 35K of the Wealth-tax Act. 47. Sub-section (1) of section 35K of the Wealth-tax Act provides that a person shall not be proceeded against for an offence under section 35A (relating to wilful attempt to evade tax, etc.) or section 35D (relating to false statement in verification, etc.) in respect of which penalty for concealment of wealth has been reduced or waived under section 18B. The applicability of the said sub-section (1) was restricted till the assessment year 1988-89 by an amendment made by the Direct Tax Laws (Amendment) Act, 1987, because penalty for concealment of wealth was omitted by the said Amendment Act. However, since penalty for concealment of wealth has been restored by the Direct Tax Laws (Amendment) Act, 1989, with effect from 1st April, 1989, it is necessary that this restriction in the applicability of the provisions of sub-section (1) of section 35K is also removed from that date. 47.1 Sub-section (1) of section 35K has, accordingly, been amen ..... X X X X Extracts X X X X X X X X Extracts X X X X
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