SABYASACHI MUKHARJI, J.

( 1 ) WE are concerned in this reference with the assessment year 1963-64, the relevant previous year being the one which ended on 31st March, 1963.

( 2 ) THE assessee is a company engaged in the manufacture of cotton textiles, rayon, yarn and also transparent paper. One of the grounds of appeal taken before the Tribunal from the order of the Income-tax Officer was in relation to taxability of a sum of Rs. 5,85,701 received by the asses-see under the export incentive scheme. In the profit and loss account for the year ended on 31st March, 1963, there was a credit of Rs. 6,00,826 which included the said sum of Rs. 5,85,701. The assessee had shown this sum in Section "f" of the return but claimed exemption from tax on the ground that the same was a casual receipt. The Income-tax Officer rejected the claim on inter alia the following grounds :"this receipt has been earned by the assessee in the course of its business as a textile manufacturer and is being accounted for by the company as a receipt year after year. The company is aware of and is regularly in expectation of this receipt on account of exports of its products and is accounting for it on the basis

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