TMI Blog1990 (11) TMI 94X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 the firm and allocated to the assessee' ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... issioner, 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 decision of this court in CIT v. Ram San ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ce 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 and allocated to the assessee's share ..... X X X X Extracts X X X X X X X X Extracts X X X X
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