TMI Blog1976 (11) TMI 7X X X X Extracts X X X X X X X X Extracts X X X X ..... " Whether, on the facts and in the circumstances of the case and in law, the Appellate Tribunal was justified in applying the decision of the Bombay High Court in the case of New Great Insurance Co. Ltd. [1973] 90 ITR 348 to the assessment year in question without considering the effect of the amendment operative from April 1, 1968, and in thus holding that the assessee would be entitled to the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Supreme Court in the case of CIT v. South Indian Bank Ltd. [1966] 59 ITR 763 as also the decision in CIT v. Industrial Investment Trust Co. Ltd. [1968] 67 ITR 436 (Bom). Mr. Joshi, however, urged before us that the question as framed in respect of which the rule has been issued can be said to deal with one of the aspects of the legal contention that was urged before the Tribunal, and as s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... " received by it " was effected and it has been explained thus : " The effect of the amendment will be that the concessional tax treatment in respect of dividends received by a company from any domestic company will be available to the recipient company even where the shares to which the dividend relates are registered in the name of a person other than the recipient company. " In view of this ..... X X X X Extracts X X X X X X X X Extracts X X X X
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