TMI Blog1989 (3) TMI 107X X X X Extracts X X X X X X X X Extracts X X X X ..... which it was constrained to discontinue in 1948. The work done by it, thereafter, consisted of looking after and maintaining its assets, the sale of plots of land owned by it and income from rent and interest. With regard to the assessment year 1977-78, a controversy arose concerning the salary said to have been paid to one Khushi Ram, an employee of the assessee. This led to the following quest ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 0, but the employee had no role to play in earning this income and, therefore, payment of salary could not be attributed wholly and exclusively for the purpose of earning income within the meaning of section 57(iii) of the Income-tax Act, 1961 (hereinafter referred to as "the Act"). It is this conclusion that led to the following question being referred, namely : "Whether, on the facts and in th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... gal expenses, travelling expenses and the like, would be expenditure incurred wholly and exclusively for the purpose of making or earning income. Seen in this light, the assessee here must indeed be held entitled to the deduction claimed. The reference is, consequently, hereby answered in the negative, in favour of the assessee and against the Revenue. There will, however, be no order as to costs. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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