1990 (11) TMI 94

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... se of five Income-tax References Nos. 65 to 69 of 1978, relating to the same assessee, in which the Income-tax Appellate Tribunal has referred the following common question for opinion of this court : "Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in holding for the assessment years 1967-68 to 1971-72, that past intangible additions made in the case of .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... l before the Appellate Assistant Commissioner, who deleted all additions except Rs. 75 for the first assessment year by giving set off in view of the additions made in the case of the firm of which the petitioner was a partner. The Revenue went up in appeal before the Income-tax Appellate Tribunal, Amritsar, against the order of the Appellate Assistant Commissioner. The Tribunal followed the deci .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... wanted to argue in the first instance that once the assessee had agreed to the addition on account of household expenses, the same could not be deleted. There is an obvious fallacy in the argument because, even now, the assessee is not disputing the additions on account of low household expenses but the argument on his behalf is whether the past intangible additions made in the case of the firm an .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X