TMI Blog1983 (1) TMI 47X X X X Extracts X X X X X X X X Extracts X X X X ..... ductors. The assessee claimed relief under section 80-I before the ITO. The ITO computed the total business income at Rs. 10,48,390 and after deducting therefrom the profits obtained by sale of the car as also the scrap sales arrived at a net figure of Rs. 10,47,519. The ITO gave relief of 5 per cent. on this which amounted to Rs. 52,376 as the relief to which the assessee will be entitled under s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by way of sale of scraps for assessment year 1972-73 ? The said question is now covered by a decision of the Supreme Court in Cambay Electric Supply Industrial Co. Ltd. v. CIT [1978] 113 ITR 84. In that case, the. Supreme Court has held that in computing the total income of the assessee carrying on the business of an industry specified under section 80E of the I.T. Act, for the purpose of the sp ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he limits of the purpose for which the fiction has been created and that the Legislature has deliberately used the expression " attributable to " intending to cover receipts from sources other than the actual conduct of the business of the specified industry. The principle laid down in the said decision squarely applies to the facts of this case. Therefore, following the said decision, the quest ..... X X X X Extracts X X X X X X X X Extracts X X X X
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