TMI Blog2002 (8) TMI 48X X X X Extracts X X X X X X X X Extracts X X X X ..... nce of the Revenue and one at the instance of the assesses arising from the order of the Income-tax Appellate Tribunal on the appeals preferred by the assessee, as also, by the Revenue which appeals arose out of the order of the Commissioner in appeal with regard to the assessment made on the assessee for the assessment year 1985-86 are now before us. The first question referred at the instance o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 6D read with section 37(3), the ceiling should be applied to the aggregate of all the tours made by the persons during the previous year and not to individual tours. This question again has already been considered by this court in the case of CIT v. Ashok Leyland Ltd. [2002] 253 ITR 425, wherein, it was held, inter alia, that the intent of rule 6D of the Income-tax Rules, clearly is that the compu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... xpenses would constitute benefit or amenity to the director and is required to be taken into account for computing the ceiling limit under section 40(c) of the Act. This question is, therefore, answered in favour of the Revenue, and against the assessee. The last question referred at the instance of the Revenue is as to whether part of the entertainment expenditure attributable to the staff of th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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