R.S.MAHENDRA, K.S.PUTTASWAMY
COMMISSIONER OF INCOME-TAX – Appellant
Versus
J. B. ADVANI AND COMPANY (MYSORE) (PRIVATE) LTD. – Respondent
( 1 ) AS parties in these cases are common and one of the questions that arises for determination is common, we propose to dispose of them by a common order.
( 2 ) MESSRS J. B. Advani and Company (Mysore) (Private) Limited, Bangalore, which is the common assessee in these cases, is inter alia engaged in the manufacture of electronic equipments such as chokes, amplifiers and T. V. antennas at its factory situated at Nasik and distribution of newsprint paper, electrodes and export of coffee, tea and pepper.
( 3 ) FOR the assessment years 1975-76 and 1976-77 relevant to the accounting years ending on march 31, 1975 and March 31, 1976 respectively, the assessee filed its returns before the income-tax Officer, Company Circle-I, Bangalore, inter alia, claiming sums of Rs. 8,881 and Rs. 9,342 respectively as deductible expenditure under Section 35b of the Income-tax Act of 1961 ("the Act"), for the aforesaid assessment years. The assessee also claimed deduction of premiums paid on an insurance policy taken out by it in the name of one Sri S. K. Sippy employed as its manager under Section 40a (5) (a) of the Act.
( 4 ) ON an examination of the returns filed by the a
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