TMI Blog1978 (7) TMI 45X X X X Extracts X X X X X X X X Extracts X X X X ..... an annual publication called " Dinesh Sure Guess ". In the assessment years 1971-72 and 1972-73, the turnover of sales of this publication was Rs. 4,84,544 and Rs. 6,10,850, respectively. It claimed a special deduction of 20% under s. 80QQ of the I.T. Act, 1961. This claim was disallowed on the ground that the publication was of the nature of brochures, tracts and pamphlets, covered by sub-s. (3) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Guess' and each of them contains a year broadly printed on the cover. Their further scrutiny shows that they are not entirely constituted of questions; instead, answer to those questions are also incorporated and it is these answers which cover substantial parts of the publications. It has been contended that instead of writing a treatise in the narrative, the assessee has, in order to help the st ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... apparent that what the assessee published was a commentary on various subjects which are in use in the schools and colleges. The book is intended to provide assistance to students appearing in examinations. It is in the form of a book, and the contents also disclosed that it is a book as understood in common parlance. Sub-section (3) of s. 80QQ makes an exception by providing that " For the purpos ..... X X X X Extracts X X X X X X X X Extracts X X X X
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