TMI Blog1983 (12) TMI 50X X X X Extracts X X X X X X X X Extracts X X X X ..... 5 of 1976 (relating to A.Y. 1970-71), I.T.R. No. 198 of 1976 (relating to A.Y 1911-72) and I.T.R's. Nos. 321 and 322 of 1979 (relating to A.Ys. 1973-74 and 1974-75) under s. 256(1) of the I.T. Act, 1961 (for short called as " the Act "), at the instance of the Department, raise one common question for the opinion of the court, namely : " Whether, on the facts and the circumstances of the case, t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Central Board of Direct Taxes issued circular No. 293, dated 10-2-1981 reading as follows : " Section 2 of the U. N. (Privileges and Immunities) Act, 1947, read with section 18, clause (b), of article V of the Schedule thereto, inter alia grants exemption from taxation to salaries and emoluments paid by the United Nations to its officials. The question whether pension received by the erstwhile o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ccepted the decision of the Karnataka High Court, but issued a circular for the guidance of the authorities under the Act. It is unfortunate that the Department has not decided to withdraw the reference applications in the case of the assessee. The view taken by the Tribunal in these references is correct. We accordingly answer these references against the Department and in favour of the assesse ..... X X X X Extracts X X X X X X X X Extracts X X X X
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