JUDGMENT

B. P. JEEVAN REDDY, J. :—This appeal is preferred against the Judgment of the Madras High Court answering the question referred to it in the affirmative i.e., in favour of the assessee and against the Revenue. The question referred under section 256(l) of the Income-tax Act reads as follows :

"Whether, on the facts and in the circumstances of the case, the Appellate Tribunal was right in holding that the total sum of Rs. 22,000/ - received by the assessee from the Indian Oil Corporation and All India Highway Motor Rally should not be brought to tax."

2. The assessment year concerned is 1974-75. The assessee, G. R. Karthikeyan, assessed as an individual, was having income from various sources including salary and business income. During the accounting year relevant to the said assessment year, he participated in the All India Highway Motor Rally. He was awarded the first prize of Rs. 20,000/ - by the Indian Oil Corporation and another sum of Rs. 2,000/- by the All India Highway Motor Rally. The Rally was organised jointly by the Automobile Association of Eastern India and the Indian Oil Corporation and was supported by several Regional Automobile Associations as well as Feder